David Fischer Quoted in Inside TSCA Article on EPA Readying TSCA Rules Governing Asbestos and Methylene Chloride

Keller and Heckman Counsel David Fischer was quoted in the Inside TSCA article, “EPA Readies Landmark TSCA Rules Governing Asbestos, Methylene Chloride.” The article discusses the U.S. Environmental Protection Agency (EPA) preparing to finalize a proposed ban on the uses of chrysotile asbestos and readying a proposal for the solvent methylene chloride that could set a long-term precedent on how the agency will approach risk management for other existing chemicals. Methylene chloride will be the first substance that the agency regulates based on its “whole chemical” approach to Toxic Substances Control Act (TSCA) risk findings. However, asbestos will not receive a “whole chemical” finding until EPA completes its “part 2” evaluation. Regarding the “whole chemical” approach, David stated this during Keller and Heckman’s December 14, 2022, TSCA 30/30 webinar: “At the end of the day, if the whole chemical risk determination approach continues to move the way this administration would like, the orders are gone, preemption based on those orders is also gone and risk management will only be for unreasonable risk as it applies to the whole chemical.”

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