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.

On June 18, 2018, Richard E. Engler, Ph.D., Director of Chemistry, Bergeson & Campbell, P.C. (B&C®) and The Acta Group (Acta®), presented “New TSCA and Green Chemistry Innovation” at the American Chemical Society’s (ACS) Green Chemistry & Engineering Conference in Portland, Oregon. This presentation covered specific changes to the Toxic Substances Control Act (TSCA) and the impact of those changes for new chemicals, including innovative “green” chemicals. In line with the conference theme, “product innovation using greener chemistries,” Dr. Engler outlined key steps to take when preparing to submit a new chemical for review, including the following items that a robust Premanufacture Notice (PMN) should include: 

  • Detailed descriptions of all potential releases and exposures throughout the supply chain, including container and equipment cleaning activities 
  • Identities of analogs that have measured data
  • All data on physical-chemical properties
     



For more information and a full copy of the presentation, contact Richard E. Engler, Ph.D., at .(JavaScript must be enabled to view this email address).


 

By Lauren M. Graham, Ph.D.

On June 15, 2017, Richard E. Engler, Ph.D., Senior Chemist at Bergeson & Campbell, P.C. (B&C®), presented at Products as Solutions to Real-World Sustainability Challenges: Incentives & Barriers, a session at the 2017 Green Chemistry & Engineering Conference (GC&E).  Dr. Engler’s presentation, “TSCA, its effects on renewable feedstocks, and how TSCA reform has changed things,” provided an overview of the Toxic Substances Control Act (TSCA) and aspects of TSCA reform that impact green chemistry, including both biobased materials and sourcing from byproducts or other wastes.  The presentation discussed how the use of a chemical substance determines TSCA regulatory requirements for the entire supply chain, including starting materials, intermediates, and catalysts (including enzymes and microbes).  To demonstrate this point, Dr. Engler reviewed scenarios under which TSCA reporting requirements for byproduct generators and processors would change based on how the byproduct is processed and used.  Dr. Engler highlighted the need for communication on TSCA reporting throughout the supply chain to ensure compliance and minimize potential commercial disruptions.
 
For more information or to request copies of the presentation materials, please contact .(JavaScript must be enabled to view this email address).