Herb Estreicher, James Votaw, and David Fischer Quoted in Chemical Watch Article on EPA to ‘Reconsider’ TSCA Prohibitions
Herb Estreicher, James Votaw, and David Fischer Quoted in Chemical Watch Article on EPA to ‘Reconsider’ TSCA Prohibitions
Keller and Heckman Partners Herb Estreicher and James Votaw and Counsel David Fischer were quoted in the Chemical Watch article, “EPA mulls process to ‘reconsider’ TSCA prohibitions after final risk management rule.” The article discusses the U.S. Environmental Protection Agency (EPA) request for feedback on a proposed approach to “expedite reconsideration” of methylene chloride prohibitions when federal agencies identify an important use after adoption of a Toxic Substances Control Act (TSCA) risk management rule.
Herb, James, and David note that TSCA does not appear to draw a distinction between federal agencies and the private sector. “Critical uses exist outside DoD supply lines,” they commented. “It is not apparent why there would be a difference between government agencies and industry bodies, considering recent compliance challenges by the private sector with TSCA prohibitions on decaBDE and PIP (3:1) that had implications for nuclear energy facilities and an array of electronics.”
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