Changes to TSCA for Small Businesses? — A Conversation with Bruce Jarnot, Ph.D.

This week, I sat down with Bruce Jarnot, Ph.D., DABT®, Senior Manager, Product Compliance, at Assent Compliance. Bruce is a board-certified industrial toxicologist with much experience assisting businesses with chemical product compliance. I have known Bruce for years, but over the past several months, Bruce and I have spoken often about the U.S. Environmental Protection Agency’s (EPA) implementation of the Toxic Substances Control Act (TSCA) and certain new rules that apply to manufacturers of finished goods, called “articles” under TSCA. Several rules issued in final this year or proposed apply to importers of finished goods and other downstream entities. A proposed reporting rule issued in June would apply to small businesses, a cohort historically exempt from TSCA reporting requirements. We discuss these rules and their significant commercial impacts, and we speculate on whether these broad reporting requirements are the new normal under new TSCA. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW. ©2021 Bergeson & Campbell, P.C.  All Rights Reserved