TSCA
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Earth Day 2023–Investing in a Balanced Approach to Emerging Contaminants

In the 1962 book, Silent Spring, Rachel Carson brought to the forefront of public attention contaminants of emerging concern (CECs). CECs, or emerging contaminants, are chemicals or materials that can be characterized by a perceived, potential or real threat to human health or the environment. Continue reading
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Governor Newsom Vetoes PFAS Reporting Bill But Signs Into Law Legislation Banning PFAS in Cosmetics and Textiles

On September 29, 2022, Governor Gavin Newsom vetoed Assembly Bill No. 2247. The bill would have required manufacturers of per- and polyfluoroalkyl substances (PFAS) or products or product components containing intentionally added PFAS to register the PFAS or products or product components on a publicly accessible data collection interface, along with other information. Continue reading
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A Risky Dance: When Emerging Contaminants Comingle With CERCLA Hazardous Substances

The distinction between CERCLA hazardous substances and all else, including pollutants or contaminants, is important because CERCLA liability is triggered by the existence of a “hazardous substance” at a site, nothing else. Continue reading
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Jenner & Block Wishes Bon Voyage to Gay Sigel as She Starts Her Next Adventure with the City of Chicago

As Gay Sigel walked through the doors at One IBM Plaza in Chicago, fresh out of law school and ready to launch her career as an attorney at Jenner & Block, she could not have envisioned the tremendous impact she would have on her clients, her colleagues, and her community over the next 39 years. Continue reading
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“Silent Spring” and the Life Cycle of Emerging Contaminants

On the 60th anniversary of the publication of Rachel Carlson’s groundbreaking book “Silent Spring”, the world continues to struggle to manage the human health and environmental risks associated with newly discovered emerging contaminants. Continue reading
Climate Change, Consumer Law and Environment, Contamination, Emerging Contaminants, Groundwater, Sustainability, TSCA, Water1, 4-dioxane, asbestos, chemicals, Corporate Environmental Lawyer, DDT, dioxin, Earth Week, Emerging Contaminants, environment, EPA, global stewardship, Groundwater, human health, Jenner & Block, MTBE, PCB, pesticides, PFAS, Rachel Carlson, Silent Spring, soil, Steven M. Siros, strategic roadmap, TSCA -
Earth Week Series: The Future of Environmental Regulation

As we near Earth Day 2022, the United States may be headed toward a profound change in the way EPA and similar administrative agencies regulate the complex areas of environmental law. EPA began operating more than 50 years ago in 1970, and has been tasked with promulgating and enforcing some of the most complex regulations… Continue reading
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Earth Week Series: Imagine a Day Without Environmental Lawyers

On this 52nd anniversary of Earth Day, I am not writing yet another, typically not very funny, riff on one of Shakespeare’s most famous lines.[1] Instead, I am inspired by one of the most popular of our blogs, written in 2017 by our talented former partner, E. Lynn Grayson, “Imagine a Day Without Water.” To… Continue reading
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TSCA Articles Regulations—U.S. EPA Course Reversal?

In prepared remarks from U.S. EPA chemicals chief Michael Freedhoff that were presented at the Product Stewardship Society’s annual meeting, Freedhoff clearly articulated an intent by the Agency to reverse course and aggressively seek to regulate finished articles under the Toxic Substances Control Act (“TSCA”). Continue reading
bioaccumulative and toxic, chemical, compliance, deadline, disposal, Hazard, import, January 2021, manufacturer, March 8 2022, Michael Freedhoff, PBT, persistent, PFAS, polyfluoralklyl, Product Stewardship Society, production volume, regulatory, Section 6(h), Section 8(a)(7), Toxic Substances Control Act, TSCA Articles Regulations, U.S. EPA -
Analysis of Recent and Forthcoming State Legislation on Toxic Chemicals in Cosmetics and Personal Care Products and Preemptive Effects of Existing Federal Legislation
According to a report released in February 2021 by the organization Safer States, at least 27 US states will consider proposed legislation to regulate toxic chemicals in 2021. While a large driver of the proposed state laws is growing public concern over drinking water contamination from “emerging contaminants,” including PFAS (per- and polyfluorinated alkyl substances)… Continue reading
adverse human health effects, California, commerce, Contamination, Cosmetics, drinking water, Emerging Contaminants, exposure, FD&C Act, Federal Food Drug and Cosmetic Act, Federal Regulation, Frank R. Lautenberg Chemical Safety Act of the 21st Century, high-priority chemicals, New York, personal care products, PFAS, polyfluorinated alkyl substances, products, regulated, risk of injury to health or environment, Safer States, Toxic Chemicals, Toxic Substrates Control Act, TSCA -
EPA Announces Plans to Require Additional Chemical Reporting under its Toxic Release Inventory

On Friday, April 30, 2021, The Biden Administration’s Environmental Protection Agency (EPA) announced significant steps the agency intends to take under the Toxics Release Inventory (TRI) Program to implement expanded reporting requirements for companies that store and utilize hazardous chemicals, including new obligations to report the storage, use and any releases of ethylene oxide, a… Continue reading
