California's Green Chemistry: The Regulations are Coming!

California is developing "Green Chemistry" regulations that could affect all businesses-including non-California companies-that make consumer products sold in the state as well as companies that manufacture chemicals used in those consumer products. In September 2008, Governor Schwarzenegger...

The Constantly Pending PMN: Low Volume Exemption Applications Are Living Documents

When available, a Low Volume Exemption ("LVE") is an attractive and quicker path to commercial marketing than filing a full premanufacture notification ("PMN") pursuant to the Toxic Substances Control Act ("TSCA"). Specifically, because LVE substances are never listed on...

Year End Nanotechnology Developments

By William J. Walsh, Of Counsel, Pepper Hamilton LLP The Environmental Protection Agency's Inspector General (IG) issued a report, EPA Needs to Manage Nanomaterial Risks More Effectively , December 29, 2011 critiquing EPA's regulation of nanomaterials (i.e., particles or fibers with a diameter...

Keller and Heckman: U.S. House of Representatives Initiates Series of Hearings to Discuss the Toxic Substances Control Act

On June 13, 2013, the House Environment and the Economy Subcommittee of the Energy and Commerce Committee held a hearing entitled “Title I of the Toxic Substances Control Act: Understanding its History and Reviewing its Impact.” Given the attention the Toxic Substances Control Act (TSCA)...

Upcoming Deadline for TSCA "Polymer Exemption" Notification

An important deadline is approaching for companies that manufacture or import polymers under the Toxic Substances Control Act (TSCA) "polymer exemption".[1] The one-time notification to the U.S. Environmental Protection Agency (EPA) that identifies the number of polymers first manufactured...

Vermont Senate Approves Pricey Green Chem Bill, Now in House’s Hands

The Vermont Senate has approved a bill, S. 239 , [ enhanced version available to lexis.com subscribers ], that would allow the state to require extensive, expensive chemical reporting and impose high fees on nearly everyone doing business in the state. All consumer products – not just children’s...