Lauren Gates Quoted in Inside TSCA Article on Fragrance Chemical HHCB Evaluation

Keller and Heckman Counsel Lauren Gates was quoted in the Inside TSCA article, “Fragrance Chemical HHCB Evaluation Likely To Face Legal Challenges.” 

The article examines the U.S. Environmental Protection Agency’s (EPA) draft Toxic Substances Control Act (TSCA) risk evaluation for HHCB, a widely used fragrance chemical, which preliminarily concludes that the substance poses no unreasonable risk to human health or the environment across all evaluated uses.

During Keller and Heckman’s November 2026 TSCA 30/30 webinar, Lauren noted the evaluation is unusual because EPA found “there are zero conditions of use that are contributing to unreasonable risk, so the chemical as a whole does not present unreasonable risk.” She described HHCB as “the most primed and poised for litigation soonest” among the current TSCA evaluations.

Lauren expects environmental groups to challenge any final no-risk determination, calling it “another bite at the TSCA section 6 [judicial] interpretation.” She noted criticism that EPA is “keeping it very narrowly focused on the top three conditions of use, so not looking at the big range of exposure.”

Lauren added that the final outcome remains important because “They just need one condition of use to contribute to the unreasonable risk” for HHCB to move into risk management, making the evaluation a potentially significant precedent for future TSCA reviews.

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