David Fischer Mentioned in Inside TSCA Article on Logical Outgrowth Concerns

Keller and Heckman Counsel David Fischer was mentioned in the Inside TSCA article, “Draft TSCA Framework’s Questions Raise Legal ‘Logical Outgrowth’ Concerns.” The article raises concerns that the final rule for TSCA risk evaluations of existing chemicals may be vulnerable to a legal challenge under the “logical outgrowth” doctrine. Related to this issue, the article notes that, among others, David has repeatedly called for defining the term “unreasonable risk,” arguing that without direction, the U.S. Environmental Protection Agency (EPA) has instead regulated on a stricter standard of ameliorating any risk.

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