This week we are pleased to have a guest post from Emilee Mooney Scott, a member of Robinson+Cole’s Environment, Energy + Telecommunications practice group. Emilee focuses her practice on environmental transactional and compliance matters, with a particular focus on the management of hazardous and toxic substances.
The Toxic Substances Control Act (TSCA) has long provided EPA with authority to review new chemical substances in a gatekeeper role as such substances enter U.S. commerce. Through amendments in 2016, EPA was also given the authority to evaluate selected existing chemical substances using a three-step framework (explained in further detail here). There are a few dozen substances in the pipeline now, with the first ten substances almost at the end of a long process that will culminate in substance-specific rules. Around the fifth anniversary of the TSCA amendments later this year, the first round of risk management rules should be proposed. These risk management rules could have significant impacts on manufacturers that use the substances in question, and will provide insight on EPA’s approach to such rules going forward. Continue Reading Chemical “Risk Management Rules” on the Horizon for 2021