David Fischer Quoted in an Inside TSCA Article on Criticisms on TSCA Evaluation ‘Framework’ Rule

Keller and Heckman Counsel David Fischer was quoted in the Inside TSCA article, “Industry Lawyers Signal Broad Attacks On TSCA Evaluation ‘Framework’ Rule.” The article examines a few different criticisms on the U.S. Environmental Protection Agency’s (EPA) newly proposed revisions to the Toxic Substances Control Act (TSCA) "framework" rule for risk evaluations of existing chemicals. David noted issues with the rule, such as its continued lack of clarity on the meaning of "unreasonable risk."

"The more rules come out, it seems like we need to come to some agreement on what unreasonable risk is," David commented.

David also argued that the "fit for purpose" concept will not alone "allow you to make statutory deadlines if you are going to make the evaluations ever more complicated. That alone won’t save you from missing deadlines."

"To me, this rule is another reason why TSCA needs to be re-reformed," David concluded, adding that revisions to "clean up some of this language" would avoid "these huge swings" in policy between administrations.

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