Section 6 Advocacy and the Importance of Being Early — A Conversation with Richard E. Engler, Ph.D.

This week I discuss with my colleague, Dr. Richard E. Engler, Director of Chemistry for B&C and The Acta Group, our consulting affiliate, the importance of engaging early and often with the U.S. Environmental Protection Agency (EPA) in the Toxic Substances Control Act (TSCA) Section 6 risk evaluation process. We discuss conditions of use (COU) of a chemical being evaluated by EPA, the reasons why educating EPA on COUs is critically important to regulated businesses, the relevance of ECELs, existing chemical exposure limits, and the consequences of a Significant New Use Rule (SNUR) for use conditions out of scope of a risk evaluation. We also discuss EPA’s evolving thinking regarding ECELs and why EPA’s thinking is a hot topic of discussion. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW. ©2023 Bergeson & Campbell, P.C.  All Rights Reserved