Bloomberg BNA Daily Environment Report Quotes Lynn L. Bergeson in "Nanoscale Materials Data Collection Rule Guidance Coming"
On May 16, 2017, Bloomberg BNA Daily Environment Report quoted Lynn L. Bergeson, Managing Partner of Bergeson & Campbell P.C. (B&C®), on upcoming guidance from the U.S. Environmental Protection Agency (EPA) on manufacturing and processing nanoengineered chemicals.
[…] Lynn Bergeson managing partner of Bergeson & Campbell, P.C. told Bloomberg BNA the EPA's decision to delay the rule's effective date until after it issues the draft guidance mutes the complaint that companies wouldn't know how to comply. It doesn't mean, however, that the guidance will be sufficient to answer companies' questions, she said by email.
"Whether the guidance that has yet to be issued provides the requisite level of detail to facilitate effective reporting remains to be seen," she said.
If the guidance is inadequate, flawed or still confusing when issued as final, some parties may argue the rule needs further to be further delayed or suspended indefinitely, Bergeson said. "But that is by no means clear."
"It does up the stakes for EPA to prepare and issue final guidance that silences concerns raised by many, many detractors, which is a tall order," Bergeson said. […]
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