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

Keller and Heckman Counsel David Fischer was quoted in the Inside TSCA article, “EPA Adopts Narrow Rule Rewriting TSCA New-Chemical Review ‘Framework.’” The article discusses the U.S. Environmental Protection Agency’s (EPA) final Toxic Substances Control Act (TSCA) rule overhauling its “framework” for reviewing new chemical uses and how it is “largely similar” to a 2023 proposal.

During Keller and Heckman’s December 4, 2024, TSCA 30/30 webinar, David described the proposal as not addressing industry concerns with the months-long review process. “As far as the proposal was concerned, none of EPA’s changes would move the needle at all. Most of the changes were sort of more cosmetic,” said David. “I haven't seen, of course, the final regs, and they may have done more, because I know a lot of public commenters had a lot of substantive comments to provide the agency, so hopefully the agency took those into consideration.”

David added that “The new EPA administration . . . could further amend the rule, depending on what the final rule looks like.” And “if they do opt to change the rule,” he continued, an industry petition he spearheaded in 2022 that sought dramatic changes to the new chemicals framework “could be a helpful roadmap” for the Trump administration.

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