Skip to main content

On June 22, 2016, after years of prior efforts, bipartisan TSCA reform legislation (H.R. 2576) was enacted as Pub. L. No. 114-182. This law made significant changes to TSCA and provides new authority for the U.S. Environmental Protection Agency (EPA) to prioritize, review, and regulate existing chemical substances. In addition to changes to EPA’s authority under TSCA, the legislation requires EPA to take a number of actions to implement modernized TSCA. 

Keller and Heckman’s TSCA practice has earned a reputation as a leader in all aspects of TSCA implementation.  In addition to our in-house scientific staff, most of whom are Ph.D. chemists, many of our attorneys have scientific academic backgrounds, including chemistry, chemical engineering, molecular biology, and environmental science. Equipped with this specialized expertise, we provide counsel on TSCA issues broadly implicated by the risk evaluation process, including Section 4 test rules and orders, chemical prioritization and management, chemical grouping issues, and reporting obligations.

Keller and Heckman’s lawyers have a comprehensive understanding of EPA’s Office of Chemical Safety and Pollution Prevention, its internal science and science policy apparatus, and its many organizational pieces that collectively are responsible for all aspects of TSCA implementation. We also host the popular monthly webinar, TSCA 30/30, a half-hour dialog covering current critical TSCA issues, as well as annual chemical control seminars of which countless TSCA practitioners have attended.

If you have any questions about TSCA compliance or need assistance navigating the regulatory landscape of chemical control, please reach out to our Chemical Control team here.

Click here for more information on the firm’s TSCA practice, including representative matters.

TSCA Implementation Center Resources

2024
January 17, 2024 – Next Wave of Prioritization Candidates
February 14, 2024 – Industry on the Counter-Attack
April 10, 2024 - TSCA §6(a) Rules - Role of Non-Risk Factors in Risk Management
May 8, 2024 - The Final Methylene Chloride Risk Management Rule: Lessons Learned by Industry
June 27, 2024 - Are You Prepared for the 2024 CDR?
July 17, 2024 - EPA Enforcement
August 14, 2024 - State of Play of TSCA Litigation
September 18, 2024 - TSCA information disclosure litigation / Are Section 21 petitions serving as an end-run around the Section 6 prioritization/risk evaluation process?
October 16, 2024 - Bypassing EPA: Citizens Use of the Courts to Regulate Existing Chemicals and Enforce TSCA (TSCA §§ 20 and 21)
December 4, 2024 - Industry Update: Fixing TSCA

2023
January 11, 2023 – TSCA Actions on EPA’s Regulatory Agenda and Cumulative Risk Assessment
February 8, 2023 – PFAS Test Orders, SNURS, Litigation, and Other Challenges
April 12, 2023 – TSCA Nomenclature–Friend and Foe
May 10, 2023 – Section 6(g) Critical-Use Exemptions
June 21, 2023 – Existing Chemicals Exposure Limits (ECELs) and Ruminations on Full Study Reports and Data Templates
July 12, 2023 – TSCA Section 6 Wake-Up Calls
August 9, 2023 – U.S. v. Inhance Case: Impurities v. Byproducts and SNURS and the Broader Implications for Industry
September 27, 2023 – The Seven Year Itch – Is it Time to Think of TSCA Reform (Again)?
October 11, 2023 – TSCA 30/30 Special 60-minute Webinar Focusing on EPA’s Final Rule to Require Reporting of PFAS Data Under TSCA
December 6, 2023 – TSCA Litigation Update