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.
Kathleen M. Roberts Presents "Achieving Critical Policy Changes Through Consortia" At ABLC2016
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On February 19, 2016, Kathleen M. Roberts, Executive Director of BRAG, presented "Achieving Critical Policy Changes through Consortia" at the 2016 Advanced Bioeconomy Leadership Conference (ABLC2016). Ms. Roberts presented as part of The Bioeconomy R&D Consortia Summit and discussed the work being done by BRAG to level the regulatory playing field for biobased chemicals. BRAG has successfully petitioned the U.S. Environmental Protection Agency (EPA) to make Chemical Data Reporting (CDR) partial reporting exemptions that are already granted to petroleum products available to biodiesel products as well. BRAG is also currently working to resolve the limitations of the Soap and Detergent Association (SDA) nomenclature system for Toxic Substances Control Act (TSCA) Inventory purposes. SDA nomenclature allows for chemical identification by alkyl range rather than source, but is limited to 35 predetermined sources. BRAG petitioned EPA on October 7, 2015, to implement, via rulemaking, a process that would broaden the sources on the SDA nomenclature list. BRAG sought to include such sources as algae and non-traditional plant materials. The petition was denied because, according to EPA, the Agency lacks the authority to initiate rulemaking under TSCA Section 8(b). EPA also claimed that BRAG did not justify the need for regulatory relief, given that the petition lacked a specific example of products experiencing this issue. While BRAG respectfully disagrees with EPA's reasoning, the denial allowed EPA to express its concurrence with BRAG's view that the SDA nomenclature is limited to the predetermined sources, and expressed a willingness to discuss approaches to address the limitation, either through changes to nomenclature guidance, or through rulemaking to establish an exemption under TSCA Section 5(h)(4). If companies wish to ensure that the SDA nomenclature list expands, they should consider joining BRAG and assist with future engagement with EPA.

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