1001 G Street NW
Suite 500 West
Washington, DC 20001
Greg Clark is a regulatory and environmental attorney with a focus on the Toxic Substances Control Act (TSCA), the Clean Air Act (CAA), the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), the Clean Water Act (CWA), the Resource Conservation and Recovery Act (RCRA), and state volatile organic compound (VOC) regulations.
Mr. Clark assists companies seeking approval of new chemical substances, genetically modified organisms, and pesticides under TSCA, FIFRA, and similar laws abroad. In this capacity, he guides clients through the Premanufacture Notification (PMN), Low Volume Exemption, Microbial Commercial Activity Notice (MCAN), and TSCA Environmental Release Application (TERA) review processes and negotiates the terms and conditions of TSCA Section 5(e) consent orders and Significant New Use Rules (SNURs). He also advises companies seeking to market biotechnology-derived products and their production platforms, including bacteria, yeast, algae, and plants, navigate the complex regulatory requirements administered by the Environmental Protection Agency (EPA), the Food and Drug Administration (FDA), and the Animal and Plant Health Inspection Service (APHIS).
Following the Lautenberg Act amendments to TSCA, Mr. Clark has advised companies and trade associations on the prioritization and risk evaluation of existing chemicals, including chemicals on the 2014 TSCA Work Plan. Within this scope, he develops detailed comments and regularly interacts with EPA staff. Additionally, Mr. Clark designs, conducts, and coordinates comprehensive internal audits of TSCA compliance for existing operations under EPA’s “Audit Policy” and other penalty mitigation policies.
Mr. Clark has extensive experience representing clients in CAA rulemakings and enforcement matters before administrative agencies, including drafting highly technical comments, filing petitions for reconsideration and judicial review, and meeting with agency staff.
Mr. Clark has a background in molecular biology and emergency preparedness.