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EPA Overhauls Rules for Evaluating Existing Chemical Risks: Three Key Takeaways for Downstream Users

Only six months after proposing to amend the procedures for risk evaluations under the Toxic Substances Control Act (TSCA), the final rule was published in the Federal Register on May 3, 2024. A flurry of activity will soon...more

EPA Eliminates De Minimis Exemption for PFAS Under TRI Reporting, Proposes Changes to Chemical Risk Evaluations Under TSCA

The U.S. Environmental Protection Agency (EPA or Agency) has issued two pre-publication announcements on notable regulatory actions that may affect your business. The first one will increase the amount of information that...more

Beware of the Looming Supply Chain Challenges for PFAS Reporting Under TSCA

Welcome back to The WELL. Let’s begin with an adaptation of the “The Ant and the Grasshopper,” when they met this summer on a field. The Grasshopper was relaxing because the final Perfluoroalkyl and Polyfluoroalkyl Substances...more

What to Expect for Risk Management Activities Under TSCA in 2023

Here is a chart for our readers on what to expect for risk management activities under TSCA in 2023. It is going to be a busy year....more

State of the Office of Chemical Safety and Pollution Prevention (OCSPP)

In today’s blog, we turn back to my favorite topic – Toxic Substances Control Act (TSCA) implementation. On June 22, it will be six years since the historic passage of the Lautenberg Amendments....more

EPA Regulation Will Impact Many Companies That Have Used PFAS in Their Products

Comment Period Extended to September 27, 2021. If you have been a manufacturer (including importer) of perfluoroalkyl and polyfluoroalkyl substances (PFAS)—commonly referred to as “forever chemicals”—since January 1, 2011,...more

New Recordkeeping and Reporting Requirements for PFAS Manufacturers – Comment Period Extended

If you have been a manufacturer (including importer) of perfluoroalkyl and polyfluoroalkyl substances (PFAS) since January 1, 2011, keep reading – you’ll want to pay close attention to a new data call from the Environmental...more

TSCA and PFAS – Important New Developments

Per- and Polyfluoroalkyl Substances (PFAS) broadly refers to the family of perfluoroalkyl and polyfluoroalkyl substances. These man-made chemicals were developed in the 1940’s and PFASs have been used to greaseproof,...more

Four Considerations for Companies that Manufacture, Import, or Process Chemicals Subject to Section 4 Test Orders

GlobalChem 2021, which just wrapped up last month, was as important as ever for the chemical industry with a number of important announcements and excellent panel presentations. I recently had a chance to look back at my...more

As 2020 Ends, the Chemical Data Reporting (CDR) Deadline Nears – Can You Avoid These Problems?

Every four years, the U.S. Environmental Protection Agency’s (EPA) CDR rule, under the agency’s Toxic Substances Control Act (TSCA) authority, requires manufacturers (and importers) to report chemical production volumes and...more

TSCA Actions - December 2020

Season’s Greetings to our WELL Readers. In today’s blog, we summarize the tremendous amount of TSCA activity this month – with more to come. What a C8 or longer PFAS surface coating is meant to be. The draft guidance was...more

The Continued Challenge Presented by Exposure Considerations in EPA Risk Evaluations

This week, Erik and I were communicating with a friend and colleague who is an expert technical consultant for TSCA risk evaluations. Specifically, we were exchanging emails on how EPA interprets conditions of use. Our...more

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