TSCA No Longer Issuing NODs for CBI Deficiencies

On January 19, 2017, the Environmental Protection Agency (EPA) announced an interpretation of Section 14 of TSCA relating to non-exempt CBI claims. This interpretation requires manufactures who make or process chemicals covered under TSCA to claim confidential business information (CBI) at the time of submittal. Starting August 15, 2019, the EPA will no longer issue […]


Smith Management Group Speaking at the 15th Annual Kentucky Chamber Conference

      Two members of SMG will be speaking on separate topics March 28 and 29, 2017 at the Kentucky Chamber Environmental Conference. Sara Smith will be sharing a session with Mike Gray, Dinsmore & Shohl LLP, discussing “TSCA Update: What You Don’t Know Can Hurt You”. Karen Thompson will be sharing a session […]

EPA Expedites Chemicals for Action

In early summer, 2016, amendments to the Toxic Substances Control Act (TSCA) were put into law.  Since then, speculation has been rampant regarding which substances would be added to the Work Plan list for risk evaluations.  You can read about the Work Plan list and speculation regarding asbestos, here.  EPA plans to list Work Plan chemicals by […]


EPA Asked to Regulate Asbestos Under New TSCA Rule

Earlier this summer, Congress significantly amended the Toxic Substances Control Act (TSCA).  You can read about the amendments here along with the implementation requirements.  A key implementation requirement and one that has been extensively discussed is the mandate that EPA designated at least 10 chemicals form its Work Plan for risk evaluations.  One of the chemicals or substances […]


EPA Publishes TSCA Reform First Year Implementation Plan

When congress passed the Frank R. Lautenberg Chemical Safety for the 21st Century Act, the act significantly amended the Toxic Substances Control Act (TSCA) which had not been updated in 40 years. With this major reform signed into law, the clock begins to tick on important deadlines and milestones that the EPA must meet in […]