David Fischer Quoted in Inside TSCA Article on TSCA High-Priority Designations

Keller and Heckman Counsel David Fischer was quoted in the Inside TSCA article, “TSCA High-Priority Designations Draw Mixed Reactions, But Little Surprise.” The article notes that on December 18, 2024, the U.S. Environmental Protection Agency (EPA) formally designated five new chemicals as “high-priority” substances that will go through risk evaluation under the Toxic Substances Control Act (TSCA).

Referring to the Obama-era Work Plan list of chemicals, David noted, “All the chemicals that EPA has initiated prioritization on are high-priority chemicals because they're pulled from that list of the 2014 chemicals. So it’s no surprise.”

However, David added that eventually, EPA will run out of chemicals on that 2014 Work Plan. “It's a finite number of chemicals, but I would have thought that perhaps EPA would have begun that process of pulling chemicals from other sources other than that 2014 list of chemicals,” he said.

David also mentioned that the Trump administration will most likely abandon Biden-era approaches such as its “whole chemical” model of identifying risk. “The new EPA in 2025 would take a very different position that reflects what was done in the first Trump administration,” he said. “And that is to look at all the different conditions of use and make an unreasonable determination based on each of those conditions of use.”

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