TSCA
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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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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
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Earth Day 2021: Heightened Chemical Regulation under the Biden Administration
A key platform of President Biden’s environmental agenda is a heightened focus on regulating chemical substances under the Toxic Substances Control Act (TSCA). Regulating chemicals in order to minimize the threat to human and the environment is clearly also critical to achieving the aims and goals of Earth Day especially considering that the publication of… Continue reading
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Biden Administration Takes New Action to Ensure Increased Consideration of Climate Change Impacts by the Federal Government

On Friday, February 19, 2021, the Council on Environmental Quality (“CEQ”) rescinded prior draft guidance issued under the Trump Administration in 2019 (the “2019 Draft CEQ Guidance”), which had restricted the need for federal agencies to consider and quantify climate change impacts under the National Environmental Policy Act (NEPA). Continue reading
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U.S. EPA Embraces Prior Administration’s PFAS Drinking Water Proposals
On February 22, 2021, U.S. EPA announced that it was moving forward with implementation of several regulatory proposals issued in the waning days of the Trump Administration. First, U.S. EPA announced that it was finalizing its regulatory determination under the Safe Drinking Water Act (SDWA) for perfluorooctanesulfonic acid (PFOS) and perfluorooctanoic acid (PFOA). Continue reading
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EPA Extends CDR Reporting Deadline
The chemical industry has received some relief from a November 30th deadline to submit information to U.S. EPA pursuant to the Chemical Data Reporting Rule (“CDR”). Section 8(a) of the Toxic Substances Control Act (“TSCA”) authorizes U.S. EPA to promulgate rules pursuant to which manufacturers and processors of chemical substances must maintain records and submit… Continue reading
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Lawsuit Filed Challenging DOJ’s Policy on Supplemental Environmental Projects
On October 8, 2020, the Conservation Law Foundation filed a lawsuit challenging a DOJ policy that barred the use of supplemental environmental projects (SEPs) in federal enforcement settlements with private parties. Continue reading
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Supreme Court Grants Review on Key Climate Change Case
On Friday, October 2, 2020, the United States Supreme Court granted a writ of certiorari to review of a decision by the Fourth Circuit Court of Appeals holding that climate change litigation brought against various fossil fuel were not subject to federal court subject matter jurisdiction. Continue reading
