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.
Renewable Chemical Stakeholders Learn Of Opportunities And Challenges They Face With TSCA
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Attendees at the Society for the Commercial Development of Industrial Biotechnology's (SCD-iBIO) 2nd Annual "Commercializing Global Green" forum in Philadelphia this week participated in a practical, in-depth three-hour workshop presented by the Biobased and Renewable Products Advocacy Group (BRAG™) on the critical policy, legislative, and regulatory issues impacting the commercialization of renewable chemicals. Lynn L. Bergeson, Managing Partner of Bergeson & Campbell, P.C. (B&C®) and Of Counsel with BRAG, shared the latest developments from Capitol Hill on the Chemical Safety Improvement Act of 2013 (CSIA) (S. 1009), in what she referred to as a "groundbreaking legislation" with bi-partisan support. Ms. Bergeson cautioned that "many difficulties remain and the likelihood of success is unclear." Ms. Bergeson also emphasized the need for the biochemical industry to engage with the U.S. Environmental Protection Agency (EPA) and identified strategies for companies to move successfully new chemicals through the regulatory process with EPA under the current version of the Toxic Substances Control Act (TSCA).


Kathleen M. Roberts, Executive Director of BRAG, updated workshop attendees on BRAG's efforts to petition for partial reporting exemptions under the TSCA Chemical Data Reporting (CDR) rule, and other efforts BRAG is making to level the regulatory playing field for biobased chemical manufacturers. Attendees learned about the complexities surrounding byproduct reporting under the CDR. They also learned that a number of listed chemicals, mainly derivative of the petroleum process stream, are exempted from Part III reporting, but those from renewable feedstocks are not, so the renewable chemicals may face higher regulatory hurdles than manufacturers anticipate. BRAG will be petitioning EPA early in 2014 for exemptions using a list of Chemical Abstract Service (CAS) numbers provided by members, and Ms. Roberts urged renewable chemical manufacturers to contact her to be included on this list.


Copies of BRAG's workshop presentations are available by contacting Chad Howlin at Tags: TSCA, workshop