B&D Principal Ryan Carra (Washington, DC) was quoted in the latest edition of Inside EPA’s, Inside TSCA in an article titled “Industry Seeks New Guidance From EPA To Ease TSCA  Article Mandates.” Ryan spoke at the American Chemistry Council’s annual GlobalChem Conference earlier in the month on a panel regarding the application of the Toxic Substances Control Act (TSCA) to articles.

Ryan, the co-leader of B&D’s Chemicals practice group, predicts that the new TSCA article regulations will require manufacturers to expect “increased coordination on TSCA issues all along the supply chain.”

As more rules are released, Ryan suggests the chemical industry will need to coordinate with article manufacturers “on the lack of appropriate alternatives to a chemical, and push that information to EPA to both of their benefits [, by] focusing on the areas of expertise [that] come most easily to them” respectively. Ryan also noted that “commenting and advocacy can be a burden” and that the coordination would be “jointly shared and contain the expertise of both” parties. This level of coordination would be new for article makers that rarely have to comply with TSCA requirements.

Ryan stated, “It’s important to tell EPA whether or not alternatives are available, [and] to tell EPA what the level of exposure is going to be. We’ve seen that type of advocacy and information being used effectively before.”

B&D’s Chemicals Regulation practice group and Chemicals industry group provide strategic, business-focused advice to the global chemicals industry. We work with large and small chemical companies whose products and activities are subject to EPA’s broad chemical regulatory authority under TSCA and state chemical restrictions.