The Biobased and Renewable Products Advocacy Group (BRAG) helps members develop and bring to market their innovative biobased and renewable chemical products through insightful policy and regulatory advocacy. BRAG is managed by B&C® Consortia Management, L.L.C., an affiliate of Bergeson & Campbell, P.C.

Bergeson & Campbell, P.C. (B&C®), the Environmental Law Institute (ELI), and the George Washington University Milken Institute School of Public Health are pleased to present the one day conference “TSCA: Three Years Later” on June 24, 2019. Panelists Alexandra Dunn, Assistant Administrator, Office of Chemical Safety and Pollution Prevention (OCSPP), EPA, and Lynn R. Goldman, Michael and Lori Milken Dean and Professor, Environmental and Occupational Health, Milken Institute School of Public Health, George Washington University, will dive into a host of topics, including the current impacts of TSCA on science policies, challenges faced by industry, and the impacts of TSCA on regulatory policies, especially those concerning ensuring compliance and enforcement. This conference (in-person and webinar) is free and open to the public, but registration is required by June 21, 2019, at the ELI website.



BCCM is pleased to announce that B&C’s podcast “All Things Chemical™” will release an episode on January 24, 2019, on biobased equivalency determination.  The “Biobased Products:  Regulatory Challenges and Proposed Solutions” podcast will provide an overview of the term “biobased” and what it means, the current nomenclature issue surrounding the biobased industry, and how BCCM’s BRAG is addressing the issue through equivalency determination.  Stay tuned for the podcast and subscribe now on iTunes, Spotify, Google Play Music, and Stitcher!  In the meantime, check out BRAG’s website for news on nomenclature issues.

Tags: B&C, Podcast


On January 8, 2019, B&C and its consulting affiliate The Acta Group (Acta®) published the 2019 Forecast.  The document details the legal, scientific, and regulatory trends in U.S. and global chemical law, providing informed judgment as to the shape of key developments we are likely to see in 2019.  Sections on biobased products and biotechnology are included in the document.  The full document can be accessed here.

Tags: B&C, Acta


On March 2, 2017, Kathleen M. Roberts, Executive Director of the Biobased and Renewable Products Advocacy Group (BRAG®), participated as a panelist alongside four other trade associations in the “Domestic Policy Forum” at the 2017 Advanced Bioeconomy Leadership Conference (ABLC2017).  Ms. Roberts discussed the challenges facing the bioeconomy, including the implementation of the amendments to the Toxic Substances Control Act (TSCA), issues with the TSCA nomenclature system, and the potential for increased scrutiny of renewable products under the current Administration, as well as the work being done by BRAG to address these challenges and to level the playing field for biobased chemicals.  If companies wish to ensure equitable regulations for biobased chemicals and products, they should consider joining BRAG to assist with future engagement with EPA.

On March 2, 2017, Richard E. Engler, Ph.D., Senior Chemist for Bergeson & Campbell, P.C. (B&C®), presented “New TSCA: How Renewable Chemicals Survive and Thrive” at ABLC2017.  Dr. Engler presented as part of the Renewable Chemicals Summit and provided an overview of amended TSCA with a focus on the fundamental changes that will impact the bioeconomy.  Amendments to TSCA Section 5 require EPA to make an affirmative determination on every new chemical review, which has resulted in significantly more regulations for new chemicals.  Additionally, under amended TSCA, Congress has the authority to preempt state action, and EPA has increased testing authorities, as well as the authority to determine chemical substances as equivalent and the authority to increase fees under Sections 4, 5, 6, and 14.  For a copy of this presentation, please contact Dr. Engler at .(JavaScript must be enabled to view this email address).



The Algae Biomass Summit is the largest algae conference in the world.  This is where leading producers of algae products go to network with industry suppliers and technology providers, where project developers converse with utility executives, and where researchers and technology developers rub elbows with venture capitalists.  Biobased and Renewable Products Advocacy Group (BRAG®) affiliate Bergeson & Campbell, P.C. (B&C®) is a proud sponsor.  B&C Senior Chemist Richard E. Engler will chair “Legal, IP, and Regulatory Challenges and Opportunities” on Tuesday, October 25, 2016.


Tuesday, September 27, 2016
8:00 a.m. Pacific Daylight Time/11:00 a.m. Eastern Daylight Time/16:00 British Summer Time

Register Today

Three months have passed since Toxic Substances Control Act (TSCA) reform was enacted, and now implementation trends are starting to take shape. Rather than waiting to see what TSCA reform's impact on your business might be, take control of your approach to "new" TSCA with the information and insight shared in "The New TSCA: What You Need To Know" webinar series presented by Chemical Watch and B&C.

Webinar 4 will cover:

  • Section 6(h) -- Chemicals That Are Persistent, Bioaccumulative, and Toxic (PBT);
  • Section 18 -- State-Federal Relationship and Preemption;
  • Section 19 -- Judicial Review; and
  • Section 26 -- Fees.

Register Online


  • Moderator -- Lynn L. Bergeson, Managing Partner, B&C;
  • Charles M. Auer, Senior Regulatory and Policy Advisor, B&C, former Director of the Office of Pollution Prevention and Toxics (OPPT), U.S. Environmental Protection Agency (EPA);
  • Richard E. Engler, Ph.D., Senior Chemist, B&C, former senior staff scientist in OPPT and leader of EPA's Green Chemistry Program;
  • Lisa R. Burchi, Of Counsel, B&C; and
  • Sheryl Lindros Dolan, Senior Regulatory Consultant, B&C.

Additional Webinars in "The New TSCA: What You Need To Know" Series:

  • Webinar 1: Overview and Summary of Major Changes: What to Expect and When to Expect It, presented June 13, 2016.
  • Webinar 2: Impacts on New Chemical Programs, presented July 14, 2016.
  • Webinar 3: Inventory, CDR, and CBI (Sections 8 & 14), presented September 12, 2016.
    • For a copy of any of these webinar recordings, click here.

Read B&C's TSCA blog for the latest news and analysis regarding TSCA reform, implementation, and related legal and administrative developments.


Scientists, executives, investors, and media representatives gathered in San Diego, California on Monday evening for a fascinating and wide-ranging panel discussion on current issues facing bioeconomy leaders and innovators. The reception, hosted by the Biobased and Renewable Products Advocacy Group (BRAG®), Bergeson & Campbell, P.C. (B&C®), and Industrial Biotechnology, included panelists Christophe Schilling, Ph.D., Founder and CEO of Genomatica; Blake A. Simmons, Ph.D., Chief Science and Technology Officer and Vice-President of the Deconstruction Division of the Joint BioEnergy Institute; and Anna Rath, President and CEO of NexSteppe and recipient of the 2016 BIO Rosalind Franklin Award honoring outstanding women in the field of industrial biotechnology. The panel took advantage of the relaxed atmosphere of Southern California and sat at a table amongst the invited guests to field questions from moderator Richard E. Engler, Ph.D., Senior Chemist with B&C, and from many of the attendees.

Asked to name the most important factor in the success of their respective companies and labs, each panelist mentioned the quality of the people on their scientific and management teams as being more critical than any other factor. In response to the question "[d]o you discover a product and then find or create a market for it, or do you notice a market opportunity and then develop a product to meet it?," all three responded that they start with a market focus and seek ways to satisfy that market need. When asked about whether regulatory or policy hurdles have impacted them at all, Ms. Rath mentioned those concerns as a factor in NexSteppe's approach to product lines and bases of operation. By creating different sorghum varieties using traditional breeding and hybridization techniques, NexSteppe can optimize its products for biofuels, biobased chemicals, bioenergy, and biogas so that its operations are not overly impacted by any one policy or regulatory change, such as the Renewable Fuel Standard (RFS) in the U.S. Dr. Schilling identified regulatory issues as one of the reasons Genomatica initially focused on applying its bioengineering processes to create sustainable versions of existing industrial chemicals, that is, chemicals already in commerce that would not face regulatory scrutiny as a new substance.

After lamenting the lack of scientists in politics, a guest somewhat jokingly asked if anyone on the panel would consider running for office. While fervently denying any chance of that (eliciting an audience member to wonder if this was only a "Paul Ryan-esque disclaimer?"), the panelists went on to point toward the many outstanding scientists working at federal agencies, in the White House Office of Science and Technology Policy (OSTP), the National Science Foundation (NSF), and in other advisory roles. Dr. Simmons particularly lauded the scientists in the 17 U.S. Department of Energy (DOE) National Laboratories, who not only create scientific breakthroughs for the benefit of U.S. business and citizens, but also advise political leaders on science issues, mentioning that after the reception, he needed to work on notes for a briefing he will give Energy Secretary Ernest Moniz later in the week. At the conclusion of the scheduled panel portion of the evening, many guests stayed to continue in conversation with the panelists, attendees, and sponsors.