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Bergeson L.L.,Bergeson and Campbell
Molecular Imaging | Year: 2011

Domestic laws, their implementing regulations and policies, and government and private-party governance programs are now being carefully reviewed and revised to enhance their utility to manage the potential risks posed by nanoscale materials. Whether existing laws and their implementing programs are adequate to address such risks will continue to inspire debate and legislative and regulatory initiatives for years to come. This article reviews existing legal and governance oversight systems and analyzes their strengths and deficiencies in addressing the potential risks posed by nanoscale materials and in fostering nanotechnology's promise. Particular attention is devoted to emerging regulatory approaches the US Environmental Protection Agency is taking under the Toxic Substances Control Act and the Federal Insecticide, Fungicide, and Rodenticide Act, the two domestic chemical product laws primarily responsible for ensuring the safety of chemical substances and mixtures. © 2011 Decker Publishing.


Bergeson L.L.,Bergeson and Campbell
Pollution Engineering | Year: 2014

A federal working group created by Executive Order 13650 issued a set of preliminary options intended to improve chemical plant security on January 3, 2014. The working group offers nine sets of options across several categories, including mandatory new safeguards. These options include clusters of issues resolution, which will have broad and enduring implications for many businesses in the chemical community. The working group is particularly interested in receiving comments on examples of where implementation of the same or similar options have been successful; information or data that would characterize the positive impacts the options might have, including additional benefits. The agencies are also considering expanding the scope of chemicals regulated under the PSM (Process Safety Management) standard and RMP (Risk Management Program) rule.


Bergeson L.L.,Bergeson and Campbell
Pollution Engineering | Year: 2014

The Occupational Safety and Health Administration (OSHA) recently proposed revisions to the injury and illness reporting and recordkeeping requirements for employers. The proposal would increase workplace safety and health through improved tracking of workplace injuries and illnesses. Under current law, employers must report the death of an employee, or the inpatient hospitalization of three or more employees, within eight hours of learning of the fatality or hospitalizations. Employers are not required to report immediately other illnesses or injuries. Specifically, OSHA is proposing to amend its current recordkeeping regulations to add requirements for the electronic submission of injury and illness information employers are already required to keep. Under current law, employers must post summaries of illness and injury reports in a common area where employees can view them. OSHA also currently makes public statistics about incidents in workplaces without describing in detail an injury, how it occurred, and more specific information.


Bergeson L.L.,Bergeson and Campbell
Environmental Quality Management | Year: 2014

Products in commerce in California are targeted, but the program has national and international implications. © 2014 Wiley Periodicals, Inc.


Bergeson L.L.,Bergeson and Campbell
ACS Sustainable Chemistry and Engineering | Year: 2013

Domestic and international laws, regulations, policies, and government and private-party governance programs are being carefully reviewed and revised to enhance their utility to nurture the commercialization of nanoscale materials. Whether existing laws are adequate to address potential risks from nanoscale materials and promote their sustainable use will inspire debate and governance initiatives for years to come. © 2013 American Chemical Society.


Bergeson L.L.,Bergeson and Campbell
Advanced Materials - TechConnect Briefs 2016 | Year: 2016

To ensure that algae biomass as a commercial feedstock is considered appropriately by federal regulators under the Toxic Substances Control Act (TSCA), the U.S. Environmental Protection Agency's (EPA) Office of Pollution Prevention and Toxics (OPPT) initiated in 2015 the Biotechnology Algae Project. OPPT has legal oversight for the production and use of intergeneric microorganisms, including cyanobacteria, eukaryotic microalgae, and their products by application of genetic engineering approaches, including processes collectively referred to as "biotechnology." EPA posted a document, US Environmental Protection Asency Biotechnology Algae Project, when it rolled out the project and notes in the document mat OPPT is focusing its project around biotechnology algae applications. This is an important initiative and stakeholders in this commercial space are urged to be aware of it and participate in it as appropriate.


Bergeson L.L.,Bergeson and Campbell
Advanced Materials - TechConnect Briefs 2016 | Year: 2016

The inclusion of manufactured nanomaterials in products is common today. So also are applications of nanotechnology in virtually every manufacturing sector of the economy. While the pace of technological innovation is furious, the unambiguous application of law, regulation, and policy, and the implications of nanotechnology for effective product stewardship are moving at far lesser speeds, creating uncertainty and potential commercial, legal, and business risk. It is, for example, far from clear what standards apply to various phases of a product's development, use, and end of life if the product contains nanoscale materials that are intended to enhance the product's efficacy and are expected to remain in the product after its useful life. While a host of private standards could apply, the precise application of legally enforceable standards is sometimes fluid, leaving product manufacturers and stewards in a quandary. In addition, because the commercial value chain can be complicated, it is not always known when a product or process involves elements of nanotechnology. Suppliers often harbor legitimate expectations of confidentiality with regard to product composition or process engineering. Such expectations, however, are sometimes difficult to align with a purchaser's desire to address all aspects of product stewardship, both actual and implied. Reconciling these expectations with meaningful and thorough product stewardship can be challenging. This paper provides a brief overview of key regulatory and legal issues of which nano innovators and others should be aware.


Bergeson L.L.,Bergeson and Campbell | Roberts K.M.,B and C Consortia Management L.L.C.
Environmental Forum | Year: 2014

The article examines how biobased chemicals have equal environmental and health potential like biofuels, including the most exposure under the Toxic Substances Control Act. Implications range from irritating to crippling, depending upon a manufacturer's responses. Market analysts predict tremendous growth in the biobased chemical industry in the years ahead. The renewable chemicals market is estimated to reach $83.4 billion by 2018. Biobased chemicals' share of the global chemical industry is expected to grow from 2 percent to 22 percent by 2025. The US could, by some estimates, replace 20 percent of its petrochemical consumption used in manufacturing with biobased products during the next ten years. The EPA review process by statute takes no less than 90 days, but as we are witnessing today, the process can take considerably longer, and typically does for new renewable chemicals. The implications of this protracted process range from irritating to crippling, depending upon how well the regulatory process has been managed by the business.


Bergeson L.L.,Bergeson and Campbell
Environmental Quality Management | Year: 2013

The proposed chemical safety improvement act would streamline TSCA. © 2013 Wiley Periodicals, Inc.


Bergeson L.L.,Bergeson and Campbell
Pollution Engineering | Year: 2011

The Department of Transportation's (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) launched a Pipeline Safety Awareness website intended to provide the public, community planners, property developers, and others accessible information and guidance on locating area pipelines and ensuring their safety. The website includes safety advisories on specific pipelines, as well as maps, reports, research findings, frequently asked questions, and other resources designed to inform the public about their local pipeline infrastructure. Due to recent pipeline incidents involving seam weld anomalies and gaps in data and recordkeeping that have hampered DOT safety initiatives, the department has embark on public meetings. The meetings will provide attendees with opportunities to obtain information, to discuss pipeline safety problems, and offer constructive solutions to these challenges.

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