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Chemical Regulation

Practices

Chemical Regulation

We advise chemical product manufacturers, distributors, importers, exporters, and users on all aspects of chemical regulation matters. We work closely with federal agencies to ensure clients receive the efficient, coordinated legal services needed to address compliance issues and enforcement actions quickly and cost-effectively.

Our national practice covers the full spectrum of federal chemical legislation, including:

  • Federal Hazardous Substances Act (FHSA)
  • Federal Insecticide, Fungicide and Rodenticide Act (FIFRA)
  • Toxic Substances Control Act (TSCA)
  • Federal Food, Drug and Cosmetic Act (FFDCA)
  • Poison Prevention Packaging Act (PPPA)

Additionally, as states increasingly regulate chemicals present in consumer products, we provide state-specific compliance counseling to assist clients in developing compliance strategies for the manufacture and sale of chemicals in targeted states.

Examples of our experience include:

  • Developing a compliance strategy for a client introducing new products into the U.S. market that triggered FHSA, TSCA, PPPA, and California Proposition 65 regulations.
  • Negotiating favorable administrative orders with U.S. EPA to resolve enforcement actions for alleged violations of TSCA CDR and import certification requirements.
  • Assisting clients with TSCA compliance audits and disclosures under U.S. EPA audit policy to avoid significant penalties for noncompliance with TSCA reporting and certification requirements.
  • Assisting clients in evaluating TSCA chemical bans and restrictions, as well as PMN, SNUR and import requirements for new chemical uses.
  • Negotiating favorable administrative orders with U.S. EPA to resolve enforcement actions for alleged violations of FIFRA requirements relating to pest products and biocides.
  • Advising clients on labeling and packaging requirements under the FHSA and PPPA.