Herb Estreicher, James Votaw, and David Fischer Quoted in Chemical Watch News & Insight Article on ‘Practicability’ Considerations in TSCA Occupational Limits

Keller and Heckman Partners Herb Estreicher, James Votaw, and Counsel David Fischer were quoted in the Chemical Watch News & Insight article, “Fight brews over ‘practicability’ considerations in TSCA occupational limits.” The article discusses the U.S. Environmental Protection Agency’s (EPA) plans to factor “practicability” into its derivation of occupational exposure limits for Toxic Substances Control Act (TSCA) risk management rules. These plans are raising questions regarding existing chemical exposure limits (ECELs).

Herb, James, and David commented, “Given the extreme uncertainty in EPA’s unreasonable risk determinations, EPA could set the ECEL in a more realistic direction.”
They also added that the EPA needs to define, or “at least put boundaries,” on what does and does not constitute ‘unreasonable risk’ under the law.

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