David Fischer Quoted in Inside TSCA Article on Methylene Chloride Rule

Keller and Heckman Counsel David Fischer was quoted in the Inside TSCA article, “Industry Attorneys See Legal Vulnerabilities In Methylene Chloride Rule.” The article refers to Keller and Heckman’s May 10, 2023 TSCA 30/30 webinar, where David urged listeners to “ponder” the sector-by-sector approach in the Environmental Protection Agency’s (EPA) newly proposed Toxic Substances Control Act (TSCA) methylene chloride rule. The rule would require some industries to stop using methylene chloride in just over one year, while others would require a 10-year phaseout paired with a stricter workplace exposure standard, known as an existing chemical exposure limit (ECEL). However, “If you comply with the ECEL, then your condition of use has met the unreasonable risk issue and no longer presents unreasonable risk,” said David. “If that's the case, then why is there a time limitation?”

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