Tom Berger and Herb Estreicher Quoted in Inside TSCA Article on Expected Increase in TSCA Correction Filings

Keller and Heckman Partners Tom Berger and Herb Estreicher were quoted in the Inside TSCA article, “‘Woefully’ Short-Handed EPA Could Face Wave Of TSCA Correction Filings.” The article discusses the expected increase in requests to correct entries on the U.S. Environmental Protection Agency’s (EPA) Toxic Substances Control Act (TSCA) Inventory of chemicals after the Agency announced that it will no longer accept new requests after April 26, 2022. Instead, EPA will require that substances that are not correctly listed on the Inventory to be reported through the lengthier TSCA pre-manufacture notice (PMN) process. During Keller and Heckman’s March 23, 2022, TSCA 30/30 webinar, Tom noted in response to the policy change that the, “ACC [is] working on this and plans to submit a detailed rebuttal to this to U.S. EPA that we support.” He went on to explain that the Agency failed to address Inventory issues related to nomenclature in 2016. In the same sentiment, Herb stated the dangers of nomenclature errors in listings asserting, “if you make a nomenclature glitch, you could be looking at millions of dollars in penalties.”

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