David Fischer Quoted in Article on ‘Binary’ TSCA Determinations Driving More Stringent Rules

Keller and Heckman Counsel David Fischer was quoted in the Inside TSCA article, “Attorney Sees ‘Binary’ TSCA Determinations Driving More Stringent Rules.” The article discusses EPA’s plan to rework its TSCA risk evaluations from considering whether individual chemical uses pose unreasonable risks, to a single “binary” risk determination for each chemical as a whole. This means the agency is all but guaranteed to apply that label to each substance it reviews, paving the way for broader rules.

David believes that the proposed change is likely to have only limited impacts. “If you have to figure out whether the chemical poses unreasonable risk, you have to figure out when its used and where and how: that’s conditions of use,” he said.

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