tsca rule Articles

  • The proposed TSCA inventory update reporting rule: big changes are in store

    While debate continues to swirl around whether, and to what extent, the Toxic Substances Control Act (TSCA) needs retooling, just about everyone agrees that the U.S. Environmental Protection Agency (US EPA) needs more information on chemical production, use, and exposure in order to make informed decisions about chemical risk management. Most also agree that TSCA could be put to greater use for ...


    By Bergeson & Campbell, P.C.

  • EPA Intends to Promulgate Final TSCA 8(a) Rule in October 2016

    According to an item in the U.S. Environmental Protection Agency’s (EPA) Fall 2015 Regulatory Agenda, EPA intends to promulgate a final Toxic Substances Control Act (TSCA) Section 8(a) rule in October 2016 concerning reporting and recordkeeping ...


    By Bergeson & Campbell, P.C.

  • The Proposed TSCA Inventory Update Reporting Rule: Big Changes Are in Store

    While debate continues to swirl around whether, and to what extent, the Toxic Substances Control Act (TSCA) needs retooling, just about everyone agrees that the U.S. Environmental Protection Agency (US EPA) needs more information on chemical production, use, and exposure in order to make informed decisions about chemical risk management. Most also agree that TSCA could be put to greater use for ...


    By Acta Group

  • TSCA - Chemical Testing Issues

    This Article introduces the Toxic Substances Control Act (TSCA),1 and describes chemical substances for which testing could be conducted under TSCA, chemical testing that could be required, persons required to conduct the tests, procedures that have been considered for selecting test chemicals, and associated legal challenges. I. TSCA The U.S. Congress enacted TSCA in 1976 to regulate ...


    By Bergeson & Campbell, P.C.

  • The Devilish Details of TSCA Reform

    On April 14, Sen. Frank R. Lautenberg, D-N.J., introduced the Safe Chemicals Act of 2011, which is intended to modernize the Toxic Substances Control Act to require chemical companies to demonstrate the safety of industrial chemicals and the U.S. Environmental Protection Agency to evaluate safety based on the best available science. ...


    By Bergeson & Campbell, P.C.

  • Act Now To Prepare for TSCA Changes

    Untitled Document The U.S. Environmental Protection Agency in 2003 significantly amended the Toxic Substances Control Act (TSCA) Section 8(a) Inventory Update Rule (IUR), ...


    By Bergeson & Campbell, P.C.

  • Could TSCA reform be coming soon?

    On April 14, 2011, Senator Lautenberg (D-NJ) introduced the Safe Chemicals Act of 2011 (S. 847) to modernize the Toxic Substances Control Act (TSCA). Lautenberg initiated similar legislation, S. 3209, in the 111th Congress. Below is a summary of key ...


    By Bergeson & Campbell, P.C.

  • Are TSCA Section 8(b)(2) Statutory Mixture Categories Subject to Reporting Under the Chemical Data Reporting Rule?

    Based on written communications from the Environmental Protection Agency’s Office of Pollution Prevention and Toxics, questions have been raised as to the agency’s interpretation of the six chemical categories created under Toxic Substances Control Act Section 8(b)(2) authority. Chemicals long considered part of these well-established categories identified decades ago are ...


    By Acta Group

  • Are TSCA Section 8(b)(2) Statutory Mixture Categories Subject to Reporting Under the Chemical Data Reporting Rule?

    Based on written communications from the Environmental Protection Agency’s Office of Pollution Prevention and Toxics, questions have been raised as to the agency’s interpretation of the six chemical categories created under Toxic Substances Control Act Section 8(b)(2) authority. Chemicals long considered part of these well-established categories identified decades ago are ...


    By Bergeson & Campbell, P.C.

  • Could TSCA Reform Be Coming Soon?

    On April 14, 2011, Senator Lautenberg (D-NJ) introduced the Safe Chemicals Act of 2011 (S. 847) to modernize the Toxic Substances Control Act (TSCA). Lautenberg initiated similar legislation, S. 3209, in ...


    By Acta Group

  • TSCA IUR Revisions Poses Challenges for Firms

    The US Environmental Protection Agency (EPA) recently proposed revisions to the Toxic Substances Control Act (TSCA) Inventory Update Rule (IUR), the consultation on which closes in October. Lynn L. Bergeson explains why domestic chemical manufacturers and importers must be aware of the proposal and prepare for its ...


    By Acta Group

  • Chemical Testing Under TSCA -- Who Is On the Hook (PDF)

    Manufacturers of chemical products and products that contain significant chemical components need to be aware of subtle but important changes in the “persons required to test” provisions of Section 4 of the Toxic Substances Control Act (TSCA).  Historically, those persons have included chemical manufacturers, processors, or those who intend to process or manufacture a Section 4 test rule ...


    By Bergeson & Campbell, P.C.

  • TSCA IUR revision poses challenges for firms

    The US Environmental Protection Agency (EPA) recently proposed revisions to the Toxic Substances Control Act (TSCA) Inventory Update Rule (IUR), the consultation on which closes in October. Lynn Bergeson explains why domestic chemical manufacturers and importers must be aware of the proposal and prepare for its implications. Background The IUR requires manufacturers, defined to ...


    By Bergeson & Campbell, P.C.

  • New Bipartisan TSCA legislation introduced in senate

    On March 10, 2015, Senators Tom Udall (D-NM) and David Vitter (R-LA) introduced the Frank R. Lautenberg Chemical Safety for the 21st Century Act, a bipartisan bill that would reform the Toxic Substances Control Act (TSCA). The bill has 15 ...


    By Bergeson & Campbell, P.C.

  • TSCA Reform - Business strategies in Times of Political Gridlock

    Change Is the Only Constant Most would agree that legislative reform of the U.S. Toxic Substances Control Act (TSCA) is long overdue. Few agree on what to change and how best to proceed. If you throw in the 2012 presidential election, you have gridlock. Commerce marches on, however, and with the Environmental Protection Agency reinventing TSCA implementation in innovative and effective ways, ...


    By Bergeson & Campbell, P.C.

  • TSCA Reform - Business strategies in Times of Political Gridlock

    Change Is the Only Constant Most would agree that legislative reform of the U.S. Toxic Substances Control Act (TSCA) is long overdue. Few agree on what to change and how best to proceed. If you throw in the 2012 presidential election, you have gridlock. Commerce marches on, however, and with the Environmental Protection Agency reinventing TSCA implementation in innovative and effective ways, ...


    By Acta Group

  • Regulatory Developments - TSCA Reform: Detailed Review of Representative Shimkus` Second Discussion Draft of TSCA Reform Legislation

    On May 12, 2015, Representative John Shimkus (R-IL), Chair of the House Energy and Commerce Subcommittee on Environment and the Economy, released a new (second) draft of the TSCA Modernization Act of 2015 (TMA2 DD). In April, Shimkus released an initial discussion ...


    By Bergeson & Campbell, P.C.

  • Deconstructing EPA's Chemical Data Reporting Rule

    The U.S. Environmental Protection Agency announced on Aug. 2, 2011, the final Toxic Substances Control Act (TSCA) Chemical Data Reporting (CDR) Rule, previously referred to as the Inventory Update Reporting (IUR) Modifications Rule. Proposed revisions to the rule were the subject of considerable debate, which helps explain the rule’s long (nearly a year and a half) gestation period ...


    By Acta Group

  • EPA proposes HPV test rule for chemicals

    Under TSCA Section 4, EPA can require manufacturers, importers, and in some cases processors of chemical substances to conduct testing of any chemical substance or mixture for which EPA makes certain findings. Under the law, EPA must find that 'there are sinsufficient data and exèrience upon which the effects of the [the] manufacture, distribution in commerce, processing, use or disposal of such ...


    By Bergeson & Campbell, P.C.

  • Deconstructing EPA's Chemical Data Reporting Rule

    The U.S. Environmental Protection Agency announced on Aug. 2, 2011, the final Toxic Substances Control Act (TSCA) Chemical Data Reporting (CDR) Rule, previously referred to as the Inventory Update Reporting (IUR) Modifications Rule. Proposed revisions to the rule were the subject of considerable debate, which helps explain the rule’s long (nearly a year and a half) gestation period ...


    By Bergeson & Campbell, P.C.

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