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Baker Botts Comments on EPA’s TSCA Framework Rules

Media Alert
WASHINGTON, June 23, 2017 - The Environmental Protection Agency (“EPA”) has released its highly anticipated final rules implementing key provisions of the 2016 Toxic Substances Control Act (“TSCA”) reform law. 

Within the rules, there will be an “inventory reset rule” that will determine the universe of existing chemicals subject to the new law's requirements, a “prioritization rule” describing how the EPA will determine which of the thousands of existing chemicals will undergo risk evaluation and another measure describing how the EPA will evaluate the risks of existing chemicals. 

The Agency also announced new guidance specifying the scientific and technical requirements for draft risk evaluations that may be submitted to EPA, as well as a group of “scoping documents” for the first ten (10) chemical substances for which EPA has already commenced its risk evaluation process under the TSCA reform law. 

“EPA has wisely incorporated helpful streamlining measures into its final rules which should, for example, help simplify the electronic notification process under the Inventory reset rule,” said Bart Seitz, Baker Botts environmental partner. 

“At the same time, industry should closely monitor upcoming developments as EPA implements its prioritization rule - particularly because EPA is planning to conduct additional stakeholder discussions about possible screening activities that could lead to prioritization for particular chemicals,” added Mr. Seitz. 

Baker Botts’ Environmental lawyers are available to discuss the EPA’s final rules on TSCA reform and what impact this will make on different industries. 


Baker Botts is an international law firm of approximately 650 lawyers practicing throughout a network of offices around the globe. Based on our experience and knowledge of our clients' industries, we are recognized as a leading firm in the energy, technology, and life sciences sectors. Since 1840, we have provided creative and effective legal solutions for our clients while demonstrating an unrelenting commitment to excellence. For more information, please visit

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