Chemical Regulation

Featured Experience

We advise clients on:

  • EPA stakeholder sessions in connection with the agency’s ongoing risk evaluation process for several designated high priority chemical substances
  • Completing the registration process under FIFRA, including addressing compensation requirements and technical consultations with EPA
  • Administrative EPCRA enforcement cases involving alleged failure to timely report accidental releases, complete necessary corrective actions, and/or file required follow-up reports federal and state authorities
  • Compliance obligations under TSCA § 12(b) for export notices, and under TSCA § 13 with respect to import certifications
  • Developing and filing “Premanufacture Notifications” (PMNs) for new chemical substances that have not yet entered commercial production
  • Compliance with Chemical Data Reporting (CDR) requirements established under TSCA § 8
  • Developing product claims and assessing product mode of action to ensure proper classification under FIFRA as a pesticide or device
  • Interpreting TRI reporting requirements for chemical use and disposal, including those for incidental byproducts
  • Preparing voluntary disclosures under EPA’s Audit Policy, including submissions under the Agency’s eDisclosure portal, regarding potential noncompliance with TSCA, EPCRA and FIFRA
  • EPA regulatory enforcement actions under TSCA, including alleged CDR noncompliance (and under the prior Inventory Update Rule (IUR) program) and violations of applicable import/export requirements
  • Regulatory compliance obligations under EU Directive 2002/95/EC on the Restriction of Hazardous Substances (RoHS) and EU Directive 2012/19/EU on Waste Electrical & Electronic Equipment (WEEE) (including recent amendments to these directives)
  • Key policy/regulatory ramifications associated with the European Union REACH program, including advice about substance information exchange forums (SIEFs) activities, and developing upstream and downstream hazard communication systems
  • FIFRA enforcement actions and “stop sale” orders
  • Assisting with regulatory agency interface on the full range of pesticides – antimicrobials, fungicides, insecticides, and herbicides – and on products for large scale agriculture as well as for household and consumer use