EPA has published a proposed regulation that is “intended to strengthen the transparency of EPA regulatory science.” Specifically, the proposed regulation limits science used in regulatory actions to data that are publicly available “in a manner sufficient for validation and analysis.” The Agency argues that the “proposal will help ensure that EPA is pursuing its […]
EPA has substantively updated the General Labeling Requirements, Precautionary Statements, and Net Contents/Net Weight Chapters of the Pesticide Label Review Manual, and made minor editorial changes throughout the rest of the manual. This manual is designed to help industry understand the pesticide labeling process and how labels should be drafted under the Federal Insecticide, Fungicide, […]
On April 24, 2018, EPA released for public comment a supplemental analysis on the definitions of small business size and their effect on Toxic Substances Control Act (TSCA) user fee collection. In the proposed fees rule EPA released in February, small businesses can quality for reduced fee amounts. For the supplemental analysis, EPA requested comment […]
Under the Environmental Protection Agency’s (EPA) Toxic Substances Control Act (TSCA) Inventory Reset Rule, manufacturers and importers were required to report all chemical substances that were active in commerce in the ten year “look-back period” ending June 21, 2016. Based on the information it received, the EPA published a draft version of the TSCA Inventory […]
EPA’s Clean Air Scientific Advisory Committee (CASAC) has now completed its review of the agency’s draft Policy Assessment (PA) for the SO2 NAAQS, and supports the EPA staff recommendation that the current scientific literature does not support revision of the current primary (health based) SO2 NAAQS. In a draft letter recently released, CASAC notes that […]
On March 13, 2018, EPA released three draft guidance documents for public comment clarifying the circumstances under which EPA may disclose TSCA confidential business information (CBI) with an expanded set of people. Comments will be accepted until April 16, 2018. Amendments to the Toxic Substances Control Act (TSCA) expanded the categories of people who may […]
On March 6, 2018, the U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit or Court) issued an unsigned per curiam opinion revising its July 2017 decision, which struck down portions of the U.S. Environmental Protection Agency’s (EPA) 2015 Definition of Solid Waste (DSW) Rule. American Petroleum Institute v. EPA, D.C. Cir. […]
On March 16, 2018, the Environmental Protection Agency (EPA or the Agency) proposed adding hazardous waste aerosol cans to the universal waste program under the federal Resource Conservation and Recovery Act (RCRA) regulations. Comments are due by April 16, 2018. Aerosol cans are widely used for dispensing a broad range of products including paints, solvents, […]
EPA recently issued new Guidance for determining whether a proposed new or modified source of air pollutants would cause a significant increase in emissions, requiring a major source permit. See Memorandum from Administrator Pruitt to Regional Administrators re: Project Emissions Accounting Under the New Source Review Preconstruction Permitting Program (March 13,2018). To date, EPA has […]
Under the proposed TSCA User Fee Rule, submitters would pay $16,000 for each PMN. This was announced on February 8, 2018, when the U.S. Environmental Protection Agency (EPA) announced that EPA Administrator Scott Pruitt signed a proposed rule regarding user fees for the administration of the Toxic Substances Control Act (TSCA). The current fee for […]
