The notice is another step in EPA’s PFAS Strategic Roadmap and emphasizes potential CERCLA enforcement. By Kegan A. Brown, Gary P. Gengel, Thomas C. Pearce, and Taylor R. West On January 12, 2023, the US Environmental Protection Agency (EPA) issued a notice to solicit public comments on its National Enforcement and Compliance Initiatives (NECI) for … Continue Reading
The Commission plans to adopt a proposal for a revised Regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals in the last quarter of 2022. By Joachim Grittmann and Alexander Wilhelm On 20 January 2022, the European Commission opened a public consultation on revising Regulation (EC) No 1907/2006 concerning the Registration, Evaluation, Authorisation and … Continue Reading
OSHA calls for comments on significant proposed amendments to align Hazard Communication Standard with the United Nations Globally Harmonized System of Classification and Labelling of Chemicals. By Julia A. Hatcher, Stijn Van Osch, Nathaniel L. Glynn*, and Jacqueline J. Yap The US Department of Labor’s Occupational Safety and Health Administration (OSHA or the agency) published a … Continue Reading
The framework represents China’s first comprehensive regulation of environmental risks from chemical substances. By Paul A. Davies and R. Andrew Westgate The Chinese Ministry of Ecology and Environment’s (MEE’s) draft Regulation on Environmental Risk Assessment and Control of Chemical Substances (Regulation) is likely to have broad implications for companies that manufacture, process, import, or export … Continue Reading
China’s MEE is seeking comment on new chemical regulation framework, which includes a comprehensive environmental risk assessment. Paul A. Davies, Ethan Prall, and R. Andrew Westgate In January 2019, China’s Ministry of Ecology and Environment (MEE) issued a draft Regulation on Environmental Risk Assessment, and Control of Chemical Substances (the Chemical Substances Regulation or CSR) … Continue Reading
Waste producers must comply with new criteria and procedures for objects and products to benefit from end of waste status. By Paul Davies The French government has developed many measures to foster circular economy approaches. Most recently, a Ministerial Order of 11 December 2018 (Order) sets out criteria and procedures to end the waste status … Continue Reading
The new department will assume broad oversight responsibilities as part of a broader government restructuring. By Paul A. Davies and R. Andrew Westgate China’s Ministry of Emergency Management (MEM) has announced the establishment of a new department responsible for the safety, supervision, and management of hazardous chemicals. The MEM replaced the former State Administration of … Continue Reading
Significant English Supreme Court decision overturns High Court and Appeal Court ruling on personal injury compensation. By Paul A. Davies and Michael D. Green Three former employees of a chemical company appealed against the decisions of the High Court and the Court of Appeal that held they could not claim against their employer for damages for … Continue Reading
By Richard P. Bress, Philip J. Perry, Andrew D. Prins, Ryan Baasch and Alexandra Shechtel On February 26, for the first time ever, a federal district court has enjoined a California Proposition 65 warning requirement on First Amendment grounds. Under California’s Safe Drinking Water and Toxic Enforcement Act of 1986 — colloquially known as “Proposition … Continue Reading
By Michael Green and Paul Davies A coalition of medical and environmental groups has called upon the European Commission (EC) to propose specific legislation that will address pollution, in particular, by active pharmaceutical ingredients (APIs). This political development highlights the complex debate currently taking place over how to identify and address the effects of APIs. … Continue Reading
By Paul Davies and Michael Green A new European Parliament briefing highlights the benefits of, and difficulties associated with, transitioning the chemicals industry to a circular economy. The traditional economy typically involves purchasing and using a product, and then disposing that product when it no longer has utility (i.e. the “take-make-dispose” approach to resources). Conversely, … Continue Reading
By Paul Davies and Michael Green On 16 June 2017, the Member State Committee (MSC) of the ECHA unanimously agreed to identify BPA as a substance of very high concern (SVHC) under the REACH regime. BPA is common in a variety of household products, typically used in the manufacture of plastics and resins found in … Continue Reading
By Paul Davies, Elisabetta Righini and Rosa Espin On 28 April 2017, the European Commission (the EC) published a “roadmap” on the strategic approach to pharmaceuticals in the environment, particularly in the aquatic environment. Concurrently, the EC launched a 12-week open public consultation to address the environmental pollution caused by human and veterinarian pharmaceutical substances. … Continue Reading
By Stacey VanBelleghem and Benjamin Lawless On January 11, 2017, the National Academies of Sciences, Engineering and Medicine (NASEM) released a report, “Valuing Climate Damages: Updating Estimation of the Social Cost of Carbon Dioxider,” recommending an updated framework for how the Federal government calculates the social cost of carbon (SCC) in regulatory rulemakings and other economically … Continue Reading
By Paul Davies, Julia Hatcher and Alice Gunn Barack Obama signed the bipartisan Frank R. Lautenberg Chemical Safety for the 21st Century Act on 22 June of this year. This Act, which came into immediate effect, amends the core provisions of the Toxic Substances Control Act (TSCA), the primary federal law governing chemicals for the … Continue Reading
By Paul Davies and Alice Gunn The European Commission published two evaluation and fitness check roadmaps in May this year. These roadmaps will assist the Commission in assessing whether the current legislative framework for chemicals, including REACH, is fit-for-purpose and delivers as expected. Together with the ongoing evaluation of 24 EU Directives in the area … Continue Reading
By Paul Davies, Andrew Westgate and Alice Gunn China’s Ministry of Industry and Information Technology (MIIT) has recently announced a revised version of the Restriction of Hazardous Substances (RoHS 1), which will come into effect on July 1, 2016. The revised legislation (RoHS 2) has significant implications for domestic and international companies manufacturing electrical and … Continue Reading
By Michael Green and Glen Jeffries The recent judgment by the European Court of Justice (ECJ) clarified the definition of “article” under the REACH Regulation 2006 ((EC) No 1907/2006). REACH is a regulation that concerns the registration, evaluation, authorisation and restriction of chemicals in the EU and REACH ensures that chemical manufacturers and suppliers that are … Continue Reading
