On February 18, 2016, Richard E. Engler, Ph.D., Senior Chemist at Bergeson & Campbell, P.C. (B&C®), presented at Cellulosic Fuels: First Commercials and Beyond, a session at the ABLC2016. Dr. Engler's presentation, 'TSCA and the Cellulosic Revolution,' covered Toxic Substances Control Act (TSCA) nomenclature, chemical Inventory, and model manufacturing process issues for cellulosic products. The presentation discussed the differences in nomenclature between Class I and Class II substances on the TSCA Inventory, and what regulatory responsibilities are triggered by different uses of substances. While cellulose is a naturally occurring substance, it is only automatically included on the Inventory if it is unprocessed or if it is processed using only a few narrowly defined methods that specifically exclude chemical modifications. This definition results in chemical notification requirements that may not be anticipated by companies unfamiliar with TSCA. Dr. Engler fielded several questions from session attendees during the Q&A period. In response to a question regarding whether biobased fuel and chemicals produced in Europe, China, or Brazil would face regulatory requirements similar to TSCA, Dr. Engler confirmed that many substances would be regulated by the European Union's (EU) Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) regulation, by Decrees Number 7 and Number 591 in China, and by similar but less well-defined programs in Brazil. He also stated that B&C affiliate The Acta Group (Acta®) offers expert guidance for companies doing business in Europe, Asia, and South America. Dr. Engler was also asked if a mixture made of substances, all of which can be found on the TSCA Inventory, would be subject to a new listing on the Inventory. He responded that a mixture of TSCA-listed substances would not be subject to additional reporting requirements, but that many biobased substances are of more variable composition, and would be considered unknown or variable composition, complex reaction products and biological materials (UVCB). He advised companies to get expert help in identifying the correct identity of their products and processes.
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Final TSCA reporting and recordkeeping rule for nanoscale materials available
On January 12, 2017, the U.S. Environmental Protection Agency (EPA) is scheduled to publish in the Federal Register a Section 8(a) of the Toxic Substances Control Act (TSCA) rule establishing reporting and recordkeeping requirements for certain chemical substances when they are manufactured or processed at the nanoscale. According to a pre-publication version of the final rule, manufacturers and processers, or persons who intend to manufacture or process these chemical substances must report certain information...
“‘The New TSCA’—What You Need To Know” Webinar 3—Inventory, CDR, And CBI (Sections 8 & 14)
Monday, September 12, 20168:00 a.m. Pacific Daylight Time/11:00 a.m. Eastern Daylight Time/16:00 British Summer Time Register Today Biobased and Renewable Products Advocacy Group (BRAG®) affiliate Bergeson & Campbell, P.C. (B&C®) and Chemical Watch have collaborated to present a series of complimentary webinars on the reformed Toxic Substances Control Act (TSCA). Webinar 3 -- Inventory, CDR, and CBI will cover: Section 8 Reporting and Retention of Information Small Manufacturer Definition;...
10 things you need to know about the new U.S. chemicals law
The updated Toxic Substances Control Act brings new hope for protecting Americans’ health and environment. Here`s what it does — and doesn’t — do. “This is a big deal,” said President Barack Obama as he signed into law the bill that updates — for the first time in 40 years — the nation’s main chemical safety legislation. Called the Frank R. Lautenberg Chemical Safety for the 21st Century Act to honor the late senator for whom this was a special cause, the law...
What Does The Loss Of “Green Chemistry” Provision From Amended TSCA Mean For Biochemicals?
On July 15, 2016, Environmental Leader published "What Does the Loss of `Green Chemistry` Provision from Amended TSCA Mean for Biochemicals?," featuring comments by Lynn L. Bergeson, Managing Partner of Biobased and Renewable Products Advocacy Group (BRAG®) affiliate Bergeson & Campbell, P.C. (B&C®). Ms. Bergeson expanded on a previous blog post titled "Inside EPA Reports On Loss Of Green Chemistry Provision From TSCA Reform," stating: "While regrettable, the absence of the green chemistry...
Seeking Guidance on TSCA Section 8C
Challenge A manufacturer of wood treatment chemicals became concerned with potential adverse chemical reactions to pressure treated wood. Although no formal letters or reports of such reactions had been reported to the EPA, the client became worried about how such reactions could impact business. Solution In response to the client’s request, Antea Group reviewed TSCA Section 8(c) regulation [40 CFR 717] and performed an extensive risk evaluation to determine potential actions and/or reporting that may be...