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...

REACH Alert: June 1, 2011- the Other Looming REACH Deadline

Now that the very important REACH deadline of 30 November 2010 for the registration of substances in high volume or high risk is passed, do not forget that another important deadline is around the corner: the notification of substances of very high concern (SVHCs) in articles. The notification...

Keller and Heckman LLP: Bipartisan Meetings on The Safe Chemicals Act of 2011

A series of stakeholder meetings on Toxic Substance Control Act (TSCA) (15 U.S.C. § 2601 et seq. ) "reform" began in the Senate on June 21, 2011. Billed as bipartisan stakeholder talks, these meetings may bring us closer to a viable TSCA reform proposal. Senate staff have advised us that...

Keller and Heckman LLP: Japan's New Chemical Reporting Requirements

On April 1, 2011, a new reporting requirement for chemicals came into effect in Japan. This new requirement originated in the 2009 amendment to Japan's chemical control law and requires that companies submit an annual report on chemical substances manufactured or imported into Japan. The first round...

California adds methyl isobutyl ketone, a widely used solvent, to the Prop. 65 list of chemicals

Methyl isobutyl ketone (CAS No. 108-10-1) is a very widely used solvent. The Office of Health Hazard Assessment (known affectionately as OEHHA [o-we-hah]) published a notice Sept. 16, 2011, that it intended to list MIK pursuant to the "labor code mechanism" (see http://www.rmkb.com/index.cfm...

Keller and Heckman LLP: Senate Holds Hearing on Safe Chemicals Act of 2011

Judging by a recent hearing, the U.S. Senate Environment and Public Works Committee appears ready to move forward with the Safe Chemicals Act of 2011 (S. 847) (SCA2011) . SCA2011 was introduced by Senator Frank Lautenberg earlier this year in his continued attempts to reform the 35-year old Toxic Substance...

Keller and Heckman LLP: Upcoming Deadline for TSCA Polymer Exemption Notification

January 31 is an important upcoming deadline 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 must identify the number of polymers first manufactured...

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...