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Toxic Substance Control Act
Regulatory and Government Affairs
  • Advise clients with respect to the Toxic Substance Control Act requirements and industry practices applicable to manufacturers, importers and exporters of chemical substances, including chemical information; health and safety study and substantial risk reporting; import certification; confidential data protection; export notification; and testing and exemption procedures, as well as a broad spectrum of issues related to Premanufacture Notification obligations and Significant New Use rule, and applicable exemptions.
  • Assist in structuring Toxic Substance Control Act compliance programs and in structuring and implementing audit programs to identify and address Toxic Substance Control Act compliance issues.
    Counsel clients in a variety of contexts on Toxic Substance Control Act's Polychlorinated Biphenyl and asbestos requirements, and represent clients in related enforcement proceedings.
  • Counseling on Section 5 notice requirements and advice regarding the preparation of pre-manufacturing notifications and bona fide intent submissions.
  • Worked with clients and their suppliers or customers to protect confidential business information.
  • Assist clients in responding to U.S. Custom’s stop shipment order relating to the importation of a chemical substance without appropriate Toxic Substance Control Act import certification papers.
  • Drafted and successfully advocated an innovative project for third-party certification for chemical imports that is now under review by Environmental Protection Agency Headquarters as an “XL” project in Environmental Protection Agency’s Environmental Leadership program.
  • Participate in national and regional workshops designed to assist natural gas distribution companies in complying with Toxic Substance Control Act Polychlorinated Biphenyl regulations.