“Contaminants Compass” is a monthly newsletter that provides updates, legal observations and actionable tips to navigate the evolving legal challenges of per- and polyfluoroalkyl substances (PFAS). This edition discusses how...more
Following several extensions to its statutory deadline, the US Environmental Protection Agency (EPA) released its final Toxic Substances Control Act (TSCA) Reporting and Recordkeeping Requirements for Per- and Polyfluoroalkyl...more
The U.S. Environmental Protection Agency (EPA) published on June 7, 2023, a final rule with new and amended requirements concerning the assertion and treatment of confidential business information (CBI) claims for information...more
In a proposed rule published on May 3, the U.S. Environmental Protection Agency recommended a ban on most uses of methylene chloride (also called dichloromethane), a common solvent and processing aid. It is used in a variety...more
EPA has proposed a special one-time reporting rule that will require businesses to go on record with the agency memorializing their contributions to PFAS in the marketplace. The final PFAS reporting rule is expected to be...more
A recent announcement by the US Environmental Protection Agency (EPA) got the immediate attention of companies that manufacture, process, or import finished products for sale and use by consumer, commercial, and industrial...more
Martha Marrapese will break down the Toxic Substances Control Act (TSCA) section 8 reporting rules on existing chemicals and the U.S. Environmental Protection Agency’s (EPA’s) planned TSCA Data Reporting (TDR) rulemaking....more
Manufacturers of chemical substances in the United States are well aware of the regulatory burdens placed on their industry by the Toxic Substances Control Act (TSCA). TSCA requirements can be cumbersome and difficult to...more
If you have unpublished studies on 50 chemicals currently under EPA’s microscope, you may need to report them to the Agency by next month. Manufacturers and importers of chemicals (including importers of articles) should...more
The EPA is expected to use its authority under TSCA to make chemical manufacturers provide more information about toxicity, exposure and other data about chemicals manufactured and imported into the U.S. market. A wide range...more
On May 12, 2020, EPA released the signed final rule updating the definition of small manufacturers, including a new definition of what is considered a small government, used to determine reporting and recordkeeping...more
One of several changes to the Toxic Substance Control Act (TSCA) Chemical Data Reporting (CDR) rule, issued in final on April 9, 2020, is that in the 2020 cycle, EPA has changed the way that toll manufacturing must be...more
On March 17, 2020, the U.S. Environmental Protection Agency (EPA) announced the availability of a final rule amending the Chemical Data Reporting (CDR) rule. According to EPA, the amendments are intended to reduce the burden...more
On April 25, 2019, EPA issued a proposed rule that would amend the TSCA Section 8(a) Chemical Data Reporting (CDR) requirements and the TSCA Section 8(a) size standards for small manufacturers. The current CDR rule requires...more
On April 12, 2019, the U.S. Environmental Protection Agency (EPA) released a proposed rule that would amend the Toxic Substances Control Act (TSCA) Section 8(a) Chemical Data Reporting (CDR) requirements and the TSCA Section...more
EPA faces many TSCA statutory and regulatory deadlines for actions in 2019 and 2020. It has also announced plans to take numerous actions not subject to such a deadline. Industry should anticipate upcoming developments and be...more
The U.S. Environmental Protection Agency (EPA) released on February 19, 2019, an update of the Toxic Substances Control Act (TSCA) Chemical Inventory (TSCA Inventory), which lists chemicals that are “active” versus “inactive”...more
Manufacturers, importers and processors of chemical substances in the United States, know full well the regulatory burdens placed on their industry by the Toxic Substances Control Act (TSCA). TSCA requirements can be...more
The U.S. EPA has released the updated Toxic Substances Control Act (TSCA) Chemical Substance Inventory (Inventory), which identifies non-confidential chemical substances designated as “active” in U.S. commerce. The April 2018...more
Inevitably, a change in Administrations leads to changes in policies and priorities of regulatory agencies. Most media coverage has focused on opposition to the Trump Administration's efforts to revise existing or proposed...more
Virtually all manufacturers and importers of chemicals for the past 11 years are now subject to a new TSCA reporting requirement known informally as the TSCA Inventory Reset. Reports will be due six months after the final...more
The U.S. Environmental Protection Agency (EPA) released on June 22, 2017, the pre-publication Federal Register notices of the final framework actions under the Toxic Substances Control Act (TSCA), as revised by the Frank R....more
With the recent release of the 2016 Chemical Data Reporting (CDR) dataset and the initial interim list of active substances released with the February 2017 copy of the Toxic Substances Control Act (TSCA) Inventory...more
The 2016 amendments to the Toxic Substances Control Act (TSCA or the Act), modified Section 8(b) of the statute to require the United States Environmental Protection Agency (EPA) to designate each chemical substance on the...more
If you manufacture or import a chemical subject to the Toxic Substances Control Act (“TSCA”) Chemical Substance Inventory, the U.S. Environmental Protection Agency (“EPA”) has proposed to require you to confirm each such...more