Bergeson & Campbell, P.C.

New Consortium Formed to Address “Fractions” and Chemical Nomenclature

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Source: Bergeson & Campbell, P.C.

B&C Consortia Management, L.L.C., an affiliate of Bergeson & Campbell, P.C., is pleased to announce the formation of the Alliance for Chemical Nomenclature (AChN), a coalition that brings together companies and organizations potentially impacted by the U.S. Environmental Protection Agency's (EPA) recent enforcement actions targeting the naming and listing of fractions of existing chemicals under the Toxic Substances Control Act (TSCA). AChN members are engaged in the manufacture or use of fractionated substances and unknown, variable, complex, or biological substances (UVCB).

AChN's goals are to make EPA aware of industry's concerns with the consequences of its newly announced enforcement initiative and understand better the relevance of EPA nomenclature guidance issued on these matters and the historical context in which these guidance documents and operating practices must be viewed. AChN is urging EPA to consider a variety of options to address cooperatively with impacted stakeholders rather than pursue enforcement actions. More detail on EPA's enforcement actions regarding 'fractions' can be found here

Interested companies or associations should .

About B&C Consortia Management, L.L.C. (BCCM) BCCM helps the chemical industry leverage resources and maximize impact by forming consortia to achieve shared research, testing, regulatory, and advocacy goals. BCCM's administrative and management support services provide consortium participants the time to focus on substantive issues, rather than administrative and organizational ones. Our goal for our consortia clients is to ensure that each consortium's interests are protected and immunized from antitrust concerns, and each one's voice is heard on a wide range of regulatory, scientific, legal, policy, and related issues.

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