David Fischer Mentioned in Inside TSCA Article on Differing Proposals for Defining Key TSCA Terms

Keller and Heckman Counsel David Fischer was mentioned in the Inside TSCA article, “Industry Offers Divergent Proposals For Defining Key TSCA Terms.” The article notes that industry groups are proposing conflicting approaches on whether and how the U.S. Environmental Protection Agency (EPA) should define key TSCA terms as it undertakes a third rewrite of the “framework” rule for evaluating risks of existing chemicals.

For example, the TSCA Risk Evaluation Reform Coalition, led by David, recently argued in its Nov. 7 comments that in practice, EPA has defined “unreasonable risk” as no risk, and it proposes an alternative to “rein in” EPA’s present approach.

The coalition’s comments deem the phrase “arguably the most important and impactful term in all of TSCA.”

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