Herb Estreicher Quoted in Article on ‘Binary’ TSCA Determinations Driving More Stringent Rules
Keller and Heckman Partner Herb Estreicher was quoted in the Inside TSCA article, “Attorney Sees ‘Binary’ TSCA Determinations Driving More Stringent Rules.” The article discusses EPA’s plan to rework its TSCA risk evaluations from considering whether individual chemical uses pose unreasonable risks, to a single “binary” risk determination for each chemical as a whole. This means the agency is all but guaranteed to apply that label to each substance it reviews, paving the way for broader rules.
“[I]f you’re selecting a chemical [as] a high priority for risk evaluation, then there must be at least one use that’s a problem,” Herb said. “That means every chemical will be branded as posing unreasonable risk.”
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