Bergeson & Campbell, P.C.’s Comments on New Category Documents under the New Chemicals Program

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Source: Bergeson & Campbell, P.C.

Bergeson & Campbell, P.C. (B&C®) appreciates the efforts being made by the U.S. Environmental Protection Agency (EPA) to upgrade and update several of the category documents in the New Chemicals Program, encourage EPA’s continued activity in this area, and encourage EPA to engage in a broader effort to solicit public comments.  We recognize the critical role that the new chemicals categories have played in the implementation of the New Chemicals Program.  Over time, however, we believe there is a need to develop and refine these documents further to inform more effectively decisions in the context of the changed requirements under Section 5 and the new Section 26 science requirements under the amended Toxic Substances Control Act (TSCA).

EPA recently shared with us four new chemicals categories with a focus on human health:  Polymer Lung Overload; Polycationic Substances (Cationic Binding); Waterproofing Agents; and General Surfactants, and we provided comments on these chemical categories.  Our comments attempt to examine the category documents under the guidance of the Section 26 science standards.

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