All Things Chemical

Bergeson & Campbell, PC

All Things Chemical is a podcast produced by Bergeson & Campbell, P.C. (B&C®), a Washington D.C. law firm focusing on chemical law, business, and litigation matters. All Things Chemical is hosted by Lynn L. Bergeson, managing partner of B&C. In each episode, we bring you intelligent, insightful, and engaging conversation about everything related to industrial, pesticidal, and specialty chemicals, as well as the law and business issues surrounding chemicals. Our incredibly talented team of lawyers, scientists, and consultants keep you abreast of the changing world of both domestic and international chemical regulation and provide analysis of the many intriguing and complicated issues surrounding this space.

All Episodes

This week I sat down with Kurt M. Landgraf, former Chairman and CEO of DuPont Pharmaceuticals Company and most recently former President of Washington College located in Chestertown, Maryland. I have known Kurt for a number of years now, and I thought a conversation focusing on Kurt’s extraordinarily diverse background would be an interesting mix of pharmaceutical management issues, higher education, and Kurt’s observations on preparing students for careers in environmental disciplines. Kurt’s storied career makes for a fascinating conversation that I think you will enjoy. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW. ©2021 Bergeson & Campbell, P.C.  All Rights Reserved

Nov 11

31 min 55 sec

David’s 1999 Paper on e-commerce and the environment This week I sat down with David Rejeski, Visiting Scholar with the Environmental Law Institute (ELI), to learn more about his engagement in the Project on the Energy and Environmental Implications of the Digital Economy. With support from the Alfred P. Sloan Foundation, ELI, the Yale School of the Environment, and the Center for Law, Energy & the Environment at UC Berkeley, the Project is shedding much-needed light on the true environmental and energy implications of the digital economy, focusing on blockchain technologies, sharing platforms, artificial intelligence, and other technologies. We also look back at David’s pioneering work on the implications of nanotechnology when he was heading up the Project on Emerging Nanotechnologies at the Woodrow Wilson International Center for Scholars. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW. ©2021 Bergeson & Campbell, P.C.  All Rights Reserved

Oct 28

48 min 13 sec

All Things Chemical will reach our 3rd anniversary on October 23rd and we want to share this celebration with you. As we look back on the last three years I wanted to bring back an older episode from the summer of 2020, “Implementing Lautenberg — A Conversation with former OPPT Director Jeffery T. Morris, Ph.D.” During this episode I spoke with Jeff Morris about how the Office of Pollution Prevention and Toxics implemented Lautenberg back in 2016, and how TSCA can be implemented in the future to address social inequities and achieve its goals of environmental justice. I hope you enjoy it and take this opportunity to listen to some more episodes from our archives. ====== This week I sat down with Dr. Jeff Morris, immediate past Director of EPA’s Office of Pollution Prevention and Toxics (OPPT), the EPA office that regulates the industrial chemical sector.  Jeff directed EPA’s implementation of the 2016 amendments to the Toxic Substances Control Act (TSCA) and headed the office most immediately impacted by the significant changes brought about by the Lautenberg amendments. In our discussion, we talk about how Jeff and his OPPT colleagues managed the daunting task of implementing a new law, and how the Agency has fared since the law’s enactment four years ago.  We discuss Jeff’s interest in environmental justice, and how TSCA might be used to address the impact of environmental harms and their disproportionate adverse impact on people of color and the poor. We also discuss Jeff’s important role in EPA’s Office of Research and Development and its research program on nanomaterials and nanotechnology, and how his background prepared Jeff well for addressing TSCA’s application to emerging chemical technologies. We conclude by learning more about what Jeff is up to now in his new role as a principal in Jeff Morris Solutions, LLC.  I really enjoyed my conversation with Jeff.  He and I have known each other for many years, and I have long admired Jeff’s integrity, his commitment to public service, and his epic understanding of chemical policy, science, and regulation. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW. ©2021 Bergeson & Campbell, P.C.  All Rights Reserved

Oct 14

57 min 20 sec

This week I sat down with my new colleague, Dennis R. Deziel, B&C’s and our consulting affiliate’s, The Acta Group, Senior Government Affairs Advisor, to discuss Toxic Substances Control Act (TSCA) reform. Dennis served as Director of Federal Government Affairs for the Dow Chemical Company when the TSCA amendments were considered and eventually enacted by Congress in 2016. After leaving Dow, Dennis served as EPA Region 1 Administrator (New England). I thought it would be interesting to speak with Dennis and seek his views on TSCA reform, as it was happening when he was a senior executive for one of the world’s largest chemical companies, and then as a Senate-confirmed political appointee, after TSCA reform was enacted and he was part of the team implementing the new law. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW. ©2021 Bergeson & Campbell, P.C.  All Rights Reserved

Sep 30

38 min 54 sec

This week I sat down with Dr. Richard E. Engler, B&C’s and The Acta Group’s (our consulting affiliate) Director of Chemistry, to discuss the U.S. Environmental Protection Agency’s (EPA) continuing struggle to regulate certain persistent, bioaccumulative, and toxic (PBT) chemicals, especially those found in finished products, what EPA refers to as “articles.” The Toxic Substances Control Act (TSCA) has always applied to the products, or articles, that contain chemical substances of interest to EPA under TSCA. While EPA previously used that authority somewhat sparingly, the 2016 Amendments to TSCA have jump-started a new wave of regulations that expressly apply to articles. EPA is required under TSCA to regulate certain PBTs, and EPA issued a final rule earlier this year that inspired chaos in the business community, especially in the electronics sector and its complicated supply chain. Rich and I discuss these PBT rules and help explain what may well be the new normal with regard to the regulation of finished products under TSCA. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW. ©2021 Bergeson & Campbell, P.C.  All Rights Reserved

Sep 16

47 min 14 sec

This week, I sat down with Daniel Rosenberg, Director, Federal Toxics Policy, Healthy People & Thriving Communities Program, at the Natural Resources Defense Council (NRDC). Daniel’s distinguished legal career has placed him at the forefront of the evolving law and policy of domestic chemical regulation. Daniel and I discuss new Toxic Substances Control Act (TSCA), the U.S. Environmental Protection Agency’s (EPA) implementation of the 2016 amendments to TSCA under Lautenberg, several recent regulatory initiatives involving persistent, bioaccumulative, and toxic (PBT) chemicals and per- and polyfluoroalkyl substances (PFAS), and much more. An engaging and formidable advocate, Daniel’s views are always forcefully spoken and clearly articulated. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW. ©2021 Bergeson & Campbell, P.C.  All Rights Reserved

Sep 2

55 min 31 sec

This week I sat down with Karin F. Baron, Senior Regulatory Consultant at B&C and our consulting affiliate, The Acta Group. Karin works extensively with the European Union’s (EU) Registration, Evaluation, Authorization, and Restriction of Chemicals, better known as REACH, which is the EU counterpart to the U.S. Toxic Substances Control Act (TSCA). We discuss REACH Article 41 “compliance checks,” an innocuous-sounding component of REACH that has the potential to cause considerable business anxiety, delay, and expense if a company’s REACH dossier is found to be deficient as a result of a compliance check. Karin walks us through what these checks are for, what could happen if you are caught up in one, and how best to respond if your dossier becomes ensnared in a compliance check. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW. ©2021 Bergeson & Campbell, P.C.  All Rights Reserved

Aug 19

45 min 54 sec

This week I sat down with Carla N. Hutton, Regulatory Analyst at B&C. Carla is also co-editor of the Nano Blog that B&C has prepared for years. Carla is uniquely well suited to discuss a report the National Institute for Occupational Safety and Health (NIOSH) recently issued on developing occupational exposure limits or “bands” for engineered nanomaterials. There are thousands of chemicals in use in the workplace, but far fewer government-issued, authoritative, peer-reviewed occupational exposure limits for workplace chemicals. The recent NIOSH report discusses an approach to evaluate scientific information to derive occupational exposure limits or bands for engineered nanomaterials. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW. ©2021 Bergeson & Campbell, P.C.  All Rights Reserved

Aug 5

26 min 54 sec

This week I sat down with Karin F. Baron, Senior Regulatory Consultant at B&C and our consulting affiliate, The Acta Group. We tackle the daunting topic of combustible dust, a common workplace hazard that is more pervasive perhaps than people think. Combustible dust poses an explosion hazard in a wide variety of industries, including food, plastic, wood, and textiles, among many others. Karin helps us understand what combustible dust includes and then walks us through the somewhat complicated governance frameworks that have emerged among the Occupational Safety and Health Administration (OSHA), private standard-setting organizations, and the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The space is crowded and remarkably unclear, especially given the severity of the incidents that have occurred over the years. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW. ©2021 Bergeson & Campbell, P.C.  All Rights Reserved

Jul 22

34 min 13 sec

This week I sat down with Dr. Richard E. Engler, B&C’s and The Acta Group’s (our consulting affiliate) Director of Chemistry, to discuss a very new component on the U.S. Environmental Protection Agency’s (EPA) PFAS Action Plan. The plan represents EPA’s “all of agency” approach to address the risks posed by per- and polyfluoroalkyl substances (PFAS) that can accumulate in humans and remain in the body for long periods. PFAS have been widely used in many consumer articles for years, and the action plan represents the totality of EPA’s actions to identify areas of risk and steps to address risks to human health and the environment. EPA recently proposed a PFAS reporting rule under the Toxic Substances Control Act (TSCA) that would compel the submission of certain information on some 1,000 listed PFAS chemicals. The proposal is controversial because of how it defines this class of chemicals, the standard of knowledge that triggers reporting, and the types of entities subject to the reporting requirements. Rich Engler helps us understand what these issues are and why you should care. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW. ©2021 Bergeson & Campbell, P.C. All Rights Reserved

Jul 8

37 min 56 sec

This week, I sat down with Bruce Jarnot, Ph.D., DABT®, Senior Manager, Product Compliance, at Assent Compliance. Bruce is a board-certified industrial toxicologist with much experience assisting businesses with chemical product compliance. I have known Bruce for years, but over the past several months, Bruce and I have spoken often about the U.S. Environmental Protection Agency’s (EPA) implementation of the Toxic Substances Control Act (TSCA) and certain new rules that apply to manufacturers of finished goods, called “articles” under TSCA. Several rules issued in final this year or proposed apply to importers of finished goods and other downstream entities. A proposed reporting rule issued in June would apply to small businesses, a cohort historically exempt from TSCA reporting requirements. We discuss these rules and their significant commercial impacts, and we speculate on whether these broad reporting requirements are the new normal under new TSCA. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW. ©2021 Bergeson & Campbell, P.C.  All Rights Reserved

Jun 24

40 min 45 sec

This week, I sat down with Meglena Mihova, Managing Partner, EPPA, the Brussels-based premier consultancy on matters involving key business sectors, including chemicals and chemical regulation. Meglena is expert on all matters involving the European Chemicals Agency (ECHA) and the complex relationships between and among ECHA, European Union (EU) member states, the European Commission, and other stakeholders. Meglena chairs the Environment Committee of the American Chamber of Commerce to the EU, which is the leading U.S. business representation body in the EU. We cover a lot of territory, including amendments to the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) regulations, the EU Green Deal, the chemicals strategy for sustainability under the EU Green Deal, and the regulation of per- and polyfluoroalkyl substances (PFAS) and microplastics. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW. ©2021 Bergeson & Campbell, P.C.  All Rights Reserved

Jun 10

51 min 32 sec

This week, I sat down with Heather J. Blankinship, Senior Manager with B&C Consortia Management, a Bergeson & Campbell affiliate, and Richard E. Engler, Ph.D., B&C’s Director of Chemistry, to discuss chemical testing under the Toxic Substances Control Act (TSCA).  Since Congress amended TSCA in 2016, EPA has been slowly ratcheting up required chemical testing under TSCA Section 4.  Congress gave EPA expanded testing authority under the 2016 Amendments, and EPA is exercising its new authority to compel chemical data production.  These test orders authorize EPA to demand the production of new test data by the manufacturers and sometimes processors of the chemical substances at issue.  Transactionally, this means competitors in the marketplace band together to generate the data EPA seeks.  We discuss the reality of quickly forming these consortia and the business and scientific challenges consortia managers face in complying with these federally enforceable test orders.  It is not as easy as you may think! ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW. ©2021 Bergeson & Campbell, P.C.  All Rights Reserved

May 27

53 min 26 sec

This week, I sat down with Brenna Finn, Assistant Attorney General, Colorado Department of Law.  I am proud to report that Brenna was a law intern here at the firm years ago, as Brenna began her legal career, and pleased to report that her experience with the firm focused her career, in part, on chemical regulation.  Brenna’s substantive skills in Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and Toxic Substances Control Act (TSCA) regulation have served her well in private practice and prepared her for her current position with the State of Colorado Attorney General’s office, where Brenna heads up the Agricultural Unit in the Business & Licensing Section of the Colorado Department of Law.  Brenna enforces the Department’s pesticide registration and application laws, among other responsibilities.  Brenna is also an adjunct law professor at the University of Denver, Sturm College of Law, where she teaches Food and Pesticide Regulation.  After briefly summarizing Brenna’s successful career, we discuss Colorado’s regulation of pesticides used on cannabis and the key enforcement issues on which Brenna’s unit focuses.  We also review other enforcement priorities in the state, as Colorado grows many crops in addition to cannabis. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW. ©2021 Bergeson & Campbell, P.C.  All Rights Reserved

May 13

59 min 41 sec

This week, I sat down with Scott J. Burya, Ph.D., a regulatory chemist with B&C and our affiliated consulting firm, The Acta Group.  Scott works extensively in the food contact area and other areas involving Federal Food, Drug, and Cosmetic Act (FFDCA) regulatory matters.  We discuss how U.S. regulatory professionals working in the all-important food contact space can leverage a European Union (EU) measure applicable to plastic food contact materials and articles.  The Plastics Implementing Measure, or PIM, includes, among other features, a list of more than 1,000 chemical substances and specific migration levels.  Scott describes the EU measure and its strengths and perceived deficits, and discusses how U.S. regulatory professionals in this space can leverage the PIM and the specific migration limits in other regulatory contexts here in the United States and elsewhere. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW. ©2021 Bergeson & Campbell, P.C.  All Rights Reserved

Apr 29

39 min 58 sec

This week, I sat down with Daniella Taveau, a Regulatory and Global Trade Strategist and the founder of Bold Text Strategies.  As a former International Trade Negotiator for the U.S. Environmental Protection Agency, Daniella represented the United States in all U.S. Free Trade Agreements and before the World Trade Organization, the United Nations (U.N.) Food and Agriculture Organization, and the Asia-Pacific Economic Cooperation.  Daniella also served as an International Policy Analyst with the U.S. Food and Drug Administration. Given Daniella’s rich background on global trade issues, we discussed the incoming Biden Administration’s approach to trade, what the Biden Trade Plan might include, what chemical and pesticide companies might expect in the months ahead, and what some of the key differences are between the new Administration’s approach to trade and the former Administration’s trade strategy. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW. ©2021 Bergeson & Campbell, P.C.  All Rights Reserved

Apr 15

44 min 51 sec

This week I sat down with Karin Baron, Senior Regulatory Consultant to B&C and our affiliated consultancy, The Acta Group, to discuss the European Union’s (EU) Commission Regulation issued last June relating to the completion of safety data sheets (SDS).  As listeners know, SDSs are critically important commercial documents that describe the hazards identified with a particular chemical product or mixture as it makes  its way in commerce.  While this is an EU rule, Karin explains why the new regulation has important consequences for U.S. businesses. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW. ©2021 Bergeson & Campbell, P.C.  All Rights Reserved

Apr 1

43 min 32 sec

This week, I sat down with Dr. Jane Vergnes, Director of Toxicology and Vice President, Scientific Affairs, here at B&C and its consulting affiliate, The Acta Group (Acta®), and Dr. Richard Engler, Director of Chemistry, at B&C and Acta.  We discussed the provocative question “is everything carcinogenic?”  In asking this question, Jane and Rich discuss the marketing and labeling implications of a cancer classification for a chemical substance found as an ingredient in a consumer or industrial product.  In today’s “informed consumer” market, product manufacturers are challenged as never before to contextualize the significance of a cancer classification or other hazard characteristic.  If Proposition 65 has taught us anything, it is that “over” warning dilutes the significance of important product information and dulls consumer awareness of information that could be communicated more meaningfully. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW. ©2021 Bergeson & Campbell, P.C.  All Rights Reserved

Mar 18

49 min 5 sec

This week I sat down with Karin Baron, Senior Regulatory Consultant to B&C and our affiliated consultancy, The Acta Group, to discuss the Globally Harmonized System of Classification and Labeling of Chemicals (GHS).  Listeners know GHS is the non-mandatory framework intended to aid in identifying, classifying, and communicating information on the hazards of chemicals or substances for occupational, consumer, and environmental exposures.  Despite the “harmonization” part in GHS, there continue to be significant areas of non-harmonization on a global scale that confound stakeholders at all levels.  For professionals working in this space, GHS can be rewarding, immensely confusing, and a bit frustrating. Karin talks a bit about the new Biden Administration and any foreseeable changes in the Occupational Safety and Health Administration’s (OSHA) implementation of the Hazard Communication Standard (HCS) and the recently proposed rule that will amend the HCS, brings us up to date on the current status of GHS Revision 9, and addresses the status of GHS more globally, especially in Canada, as what is going on with our northern neighbors is always significant for U.S. businesses. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW. ©2021 Bergeson & Campbell, P.C.  All Rights Reserved

Mar 4

38 min 45 sec

This week, I sat down with Jim Aidala, Senior Government Affairs Consultant, and Dr. Richard Engler, Director of Chemistry, at B&C and its consulting affiliate, The Acta Group.  As both of these gentlemen previously worked at the U.S. Environmental Protection Agency’s (EPA) Office of Chemical Safety and Pollution Prevention, Jim as former Assistant Administrator of that office and Rich as a senior chemist and head of the Green Chemistry Division, each has a keen sense of how EPA prepares for and transitions to a new Administration.  After reviewing how a new Administration fills key positions and otherwise prepares to take the reins, we discuss a few topics on everyone’s mind -- what we can expect from a Biden EPA on critical topics like climate change, environmental justice, TSCA implementation, pesticide policy, and more.  EPA policies are always front and center in a new Administration, but with climate issues bearing down, the stakes are even more consequential in this transition. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW. ©2021 Bergeson & Campbell, P.C.  All Rights Reserved

Feb 18

45 min 41 sec

A change in Administration invites a sense of both excitement and anxiety.  Nowhere is this ambivalence more present that in the minds of regulated entities subject to the Toxic Substances Control Act (TSCA).  After four years of the Trump Administration’s implementation of the many TSCA amendments occasioned by Lautenberg, regulated entities and other stakeholders have come to understand the U.S. Environmental Protection Agency’s (EPA) interpretation of revised TSCA.  Not everyone agrees with these views, but they are known.  What is unclear is whether the Biden Administration will continue these interpretations or go back to the drawing board. This week I sat down with Richard E. Engler, Ph.D., B&C’s Director of Chemistry, to explore exactly this question.  We discuss some of the many uncertainties facing businesses as we approach inauguration day.  Key new terms like “conditions of use” and “reasonably foreseen” have been defined over the past years, and regulated entities have much riding on their known definitions.  Rich walks us through how a new Administration might see things differently and what businesses might expect in the months ahead.  Rich also shares his view on how the Trump EPA is doing in meeting its statutory obligations under TSCA, how the Courts are viewing EPA’s implementation efforts, and what to watch out for in the Biden EPA. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW. ©2021 Bergeson & Campbell, P.C.  All Rights Reserved

Feb 4

48 min 40 sec

This week I had my final visit with the U.S. Environmental Protection Agency’s (EPA) Assistant Administrator Alexandra Dunn.  As many of our listeners know, Alex Dunn heads the Office of Chemical Safety and Pollution Prevention and is responsible for implementing the nation’s industrial and agricultural chemical laws, the Toxic Substances Control Act (TSCA) and the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), respectively.  Alex has done a superb job since taking office in early 2019, and her steady hand in managing TSCA implementation and a wide range of hot button pesticide issues has been effective and comforting. Prior to Alex’s current role, she served as the Regional Administrator for EPA Region 1, and before Region 1, Alex served as the executive director and general counsel for the Environmental Council of the States. We focused our discussion on a look back at Alex’s many achievements since taking office, including implementation of the amendments to TSCA, which Congress enacted in 2016.  Alex also addressed some of the most controversial pesticides -- glyphosate, dicamba, and chlorpyrifos, among others -- all the while implementing one of the most consequential pieces of environmental legislation ever passed by Congress. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW. ©2021 Bergeson & Campbell, P.C.  All Rights Reserved

Jan 21

50 min 33 sec

This week I sat down with my friend and colleague, Howard Gutman, who served as Ambassador to Belgium in the Obama Administration and is now a consultant for global businesses.  Ambassador Gutman addresses a broad range of timely and important topics, including the 2020 elections and what happened exactly, and what CEOs should be thinking about because of the change in Administration, both for U.S.-based and foreign-based businesses.  Given Ambassador Gutman’s unique view of global business, we also touch upon the European Union’s precautionary principle and regulatory decision-making, European and American views on big tech, and some of the biggest challenges to global growth. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW. ©2021 Bergeson & Campbell, P.C.  All Rights Reserved

Jan 7

41 min 47 sec

This week I was thrilled to sit down with Kate Sellers, Technical Director at ERM, where Kate leads multidisciplinary teams to help clients meet their business goals through product stewardship and sustainability initiatives.  Kate is immediate past President of the Product Stewardship Society and one of the country’s most visionary leaders in the area of product stewardship.  Kate counsels some of the largest companies in the world on optimizing business practices to producer better, safer products in a sustainable and efficient way.  I have known Kate for years, and believe me, when Kate speaks, business leaders listen. We discuss why now more than ever, businesses need to be sustainable, to shift from a linear to a circular economy, and to understand how to integrate product stewardship principles and practices into their business dealings.  We also discuss the impact of the European Union’s chemical strategy for sustainability on U.S. companies, COVID-19’s influence on supply chain systems, the role of Artificial Intelligence in governance, and other fascinating topics.  After listening to this podcast, you will know why Kate’s practice is thriving and she is in demand as a speaker and presenter. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW. ©2020 Bergeson & Campbell, P.C.  All Rights Reserved

Dec 2020

33 min 36 sec

This week I sat down with Dr. Jeff Morris, immediate past Director of EPA’s Office of Pollution Prevention and Toxics (OPPT), the EPA office that regulates industrial chemicals.  Jeff is now a principal of Jeff Morris Solutions LLC, a consulting firm helping entities navigate the complexities of industrial chemical regulation.  While at EPA, Jeff directed the Agency’s implementation of the 2016 amendments to the Toxic Substances Control Act (TSCA), the U.S. law regulating industrial chemicals, and headed the office most immediately impacted by the significant changes brought about by the Lautenberg amendments. In our discussion, we look back on Jeff’s leadership of the Office of Pollution Prevention and Toxics and its accomplishments in implementing Lautenberg, which policies the current Administration has implemented that should continue, and how the new Administration should and can do more using TSCA to address social inequities and achieve the goals of environmental justice.  Jeff discusses his recent articles on this important topic, as well as the important role international collaboration plays in understanding both the commercial promise and chemical profile of nanomaterials. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW. ©2020 Bergeson & Campbell, P.C.  All Rights Reserved

Dec 2020

54 min 11 sec

This week, my colleague, Dr. Jane Vergnes, and I sat down with Bjorn Hansen, Executive Director of the European Chemicals Agency (ECHA).  As our listeners may know, ECHA is the European Union (EU) regulatory agency charged with managing the scientific, technical, and administrative aspects of chemical management programs in the EU, including the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH), the Classification, Labeling, and Packaging Regulation (CLP), the Biocidal Products Regulation (BPR), the Prior Informed Consent Regulation (PIC), and a definition of substances of very high concern (SVHC).  Bjorn leads approximately 600 employees, many of whom are located in Helsinki, where ECHA’s offices are located.  In addition to speaking about the imminent end of the transition period between the EU and Great Britain under Brexit, which has been no small endeavor, Bjorn discusses the very recent issuance of the EU Chemicals Strategy for Sustainability Towards a Toxic-Free Environment.  Issued on October 14, 2020, this new Strategy includes some 50 initiatives intended to complement the European Green Deal announced last December, under which the EU has committed to no net greenhouse gas emissions by 2050. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW. ©2020 Bergeson & Campbell, P.C.  All Rights Reserved

Nov 2020

48 min 2 sec

This week, I sat down with Dr. Jane Vergnes, Director of Toxicology here at B&C and Vice President, Scientific Affairs, and Director of Toxicology at B&C’s consulting affiliate, The Acta Group.  Jane has lead responsibility for our United Kingdom (UK) and Brussels offices and has been deeply engaged in Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) and the impact of Brexit on our European Union (EU), UK, and U.S. clients. Given the fast approaching end of the transition period between the UK and EU, I thought it would be timely to parachute in and see what is top of the mind for companies in the chemical space with regard to what to expect in the New Year, and to check in on what else is front and center across the Pond, as it were.  Jane and I discuss the transition period, the new UK REACH law, what is actually happening on the ground as we approach the end of the transition period, and a few other hot topics in the EU, including new obligations issued by the Commission recently of which EU REACH registrants must be aware.  As Brexit also applies to biocides and plant protection products, we also touch upon biocides and agricultural chemicals and what to expect at the end of the year.  Brexit has invited no small amount of uncertainty and anxiety for chemical stakeholders, especially against the backdrop of an already uncertain, pandemic-challenged world.  My conversation with Jane provides some comforting clarity and useful thoughts on what to do as the transition period comes to an end. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW.

Oct 2020

53 min 33 sec

This week, I sat down with Lisa Campbell, my Partner here at Bergeson & Campbell (B&C®) and its consulting affiliate, The Acta Group (Acta®), and a well-recognized expert on all things regulated under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).  With so much attention focused on registering new products to combat COVID-19, we thought it timely to check in again with the U.S. Environmental Protection Agency (EPA) Office of Pesticide Programs (OPP) and see what it is up to.  OPP has been extraordinarily busy since March keeping up with new products to combat the coronavirus and forging new ways of leveraging its resources while maximizing the public health benefits of these new products. We also discuss the government’s heightened interest in ensuring that marketers of products -- new and existing -- are precluded from placing products on the market that EPA believes are not effective against COVID-19, when they are promoted as effective against the virus.  EPA has been quite aggressive in ensuring that products that claim to be effective in fact are effective. We then update our listeners on a few other OPP developments unrelated to the pandemic, as OPP’s jurisdiction extends far beyond approving new products to address COVID-19. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL AND ENTERTAINMENT PURPOSES.  THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES.  ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW. ©2020 Bergeson & Campbell, P.C.  All Rights Reserved

Oct 2020

41 min 30 sec

This week, I sat down with Jim Aidala, Senior Government Affairs Consultant at B&C and its consulting affiliate, The Acta Group.  As a former Assistant Administrator in what is now the U.S. Environmental Protection Agency’s (EPA) Office of Chemical Safety and Pollution Prevention, Jim has a keen sense of how EPA prepares for and transitions to changes in Administrations.  As we prepare for the November elections, we thought it would be good to check-in with Jim and get a sense of how our colleagues at EPA are faring.  After reviewing key topics in the pesticide world, Jim walks us through how and when pesticide registrants and others in the commercial value chain can prepare for any forthcoming transition, consequential or otherwise.  Jim discusses whether regulated entities can expect policy changes occasioned by a new Administration, regardless of who wins.  Jim also addresses the implications of changes in the Supreme Court in light of Justice Ginsburg’s death. Jim’s insights in these areas is spot on and timely.   ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW.   ©2020 Bergeson & Campbell, P.C.  All Rights Reserved

Oct 2020

48 min 57 sec

This week I sat down with Vincent Caprio, Founder and Executive Director of the NanoBusiness Commercialization Association (NanoBCA).  Vince has been on the forefront of nano innovations and optimizing opportunities for businesses to commercialize their nano creations for more than two decades.  In founding the NanoBCA, Vince has placed it at the center of nanotechnology commercialization, national policy, law, and business since the beginning of the public’s focus on nanotechnology.  NanoBCA has provided a much-needed spotlight on how nanotechnology has been a critical driver for the development of advanced materials, smart technology, innovations in chemistry, and a diverse range of other initiatives that have greatly benefited many economic sectors of the economy.  As Chair of the Environment, Health, and Safety (EHS) Committee of the NanoBCA, I have long admired Vince’s vision, organization-building skills, and his seemingly endless list of contacts -- there is no one in Washington, D.C., or elsewhere, whom Vince does not know! In our conversation, Vince shares a bit about the early days of nanotechnology, how NanoBCA helped frame critical EHS issues in a way that moved the technology forward, his relationship with and deep engagement in the activities of the National Nanotechnology Initiative, his engagement with key Senators and Representatives on nano matters, and what’s next for nanotechnology after the 2020 elections. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW. ©2020 Bergeson & Campbell, P.C.  All Rights Reserved

Sep 2020

40 min 33 sec

This week I sat down with Sheryl Lindros Dolan, Senior Regulatory Consultant at B&C and its consulting affiliate, The Acta Group.  Sheryl is on the front line of pesticide registration and engages in a remarkably diverse range of pesticides and pesticide devices.  Sheryl is particularly gifted at charting regulatory strategies for new and novel pesticide innovations and other agricultural chemical products like biostimulants, biopesticides, and other chemical products.  Sheryl’s training as a scientist and a lawyer is invaluable in guiding clients to obtaining their regulatory approvals swiftly and efficiently. Our conversation covers a broad range of topics beginning with a check-in with how the U.S. Environmental Protection Agency’s (EPA) Office of Pesticide Programs is faring under our now not-so-new pandemic-focused times.  We discuss how EPA is addressing the greatly increased number of pesticide registration applications in response to the COVID-19 virus, the submission of emergency exemption applications under FIFRA Section 18, and how to manage client expectations, especially those harbored by innovators who believe their products will help protect against the virus and thus have a sense of urgency that is challenging to align with even accelerated government approval time lines. We also discuss EPA’s compliance advisory for pesticide devices making coronavirus claims and EPA’s continuing efforts to prevent the marketing of bogus products that are unregistered and thus illegal.  Sheryl’s expertise and broad experience in these areas make for a great conversation. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW.

Sep 2020

32 min 11 sec

This week I sat down with Dr. Jeff Morris, immediate past Director of EPA’s Office of Pollution Prevention and Toxics (OPPT), the EPA office that regulates the industrial chemical sector.  Jeff directed EPA’s implementation of the 2016 amendments to the Toxic Substances Control Act (TSCA) and headed the office most immediately impacted by the significant changes brought about by the Lautenberg amendments. In our discussion, we talk about how Jeff and his OPPT colleagues managed the daunting task of implementing a new law, and how the Agency has fared since the law’s enactment four years ago.  We discuss Jeff’s interest in environmental justice, and how TSCA might be used to address the impact of environmental harms and their disproportionate adverse impact on people of color and the poor. We also discuss Jeff’s important role in EPA’s Office of Research and Development and its research program on nanomaterials and nanotechnology, and how his background prepared Jeff well for addressing TSCA’s application to emerging chemical technologies. We conclude by learning more about what Jeff is up to now in his new role as a principal in Jeff Morris Solutions, LLC.  I really enjoyed my conversation with Jeff.  He and I have known each other for many years, and I have long admired Jeff’s integrity, his commitment to public service, and his epic understanding of chemical policy, science, and regulation. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW. ©2020 Bergeson & Campbell, P.C.  All Rights Reserved

Aug 2020

55 min 59 sec

This week I sat down with Richard E. Engler, Ph.D., B&C’s Director of Chemistry, and all-around TSCA savant. Rich is an organic chemist and a 17-year veteran with the U.S. Environmental Protection Agency’s (EPA) Office of Pollution Prevention and Toxics, where Rich managed the Green Chemistry Program and reviewed some 10,000 new chemical notifications. Given all that is going on at EPA with implementing the Frank R. Lautenberg Chemical Safety for the 21st Century Act, which extensively amended the Toxic Substances Control Act (TSCA), Rich and I discussed a wide range of ongoing and planned EPA initiatives.  These include EPA’s risk evaluations under TSCA Section 6, progress EPA has made in reviewing new chemicals and work that remains to be done, how EPA has responded to staff and resources challenges, key ongoing litigations challenging various aspects of TSCA implementation, and what to look for as we approach the end of the calendar year and the impact of the pending National election.  Rich’s insights are always fascinating and enlightening, and our conversation is sparkling and entertaining. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW.

Aug 2020

45 min 11 sec

This week I sat down with Congressman John M. Shimkus, a Member of the United States House of Representatives for the 15th District of Illinois.  As listeners of the podcast know well, Congressman Shimkus is a senior Member of the House Energy and Commerce Committee.  In this capacity, Congressman Shimkus has become a rock star in the industrial chemical community, given his tireless efforts to modernize the Toxic Substances Control Act (TSCA) , which of course resulted in passage four years ago of the Frank R. Lautenberg Chemical Safety for the 21st Century Act (Lautenberg). Given Congressman Shimkus’s extensive involvement in and personal commitment to reforming TSCA, our conversation focused on the efforts that have been under way since June 2016 to implement the massive and complicated new law.  We address many aspects of Lautenberg’s implementation, not just by the U.S. Environmental Protection Agency (EPA), but also efforts under way by other industrial chemical stakeholders, including industry, non-government organizations (NGOs), states, and the courts.  We discuss the many, many rulemakings EPA has issued since 2016 and survey the next leg of EPA’s journey to implement the new law over the next 12 to 24 months, which will be extremely busy.  Congressman Shimkus is as passionate today as he was four years ago about chemical safety, as you will hear in this recording. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW.

Jul 2020

35 min 41 sec

This week I sat down with James Aidala, B&C’s Senior Government Affairs Consultant, to catch up on what the U.S. Environmental Protection Agency’s (EPA) Office of Pesticide Programs (OPP) is up to and to get a sense of what we might expect to develop over the remainder of the year.  As a former Assistant Administrator of what is now the Office of Chemical Safety and Pollution Prevention, Jim’s thoughts and analyses are always spot on. We discuss leadership within OPP, which is transitioning.  Not surprisingly, who holds the position of Office Director is always of great interest to the agricultural and biocidal chemical communities. We also touch upon a number of high-profile pesticide science policy debates about substances, some of which have been raging literally for years.  These substances include dicamba, glyphosate, and chlorpyrifos.  The legal and scientific administrative and judicial reviews under way in the United States and internationally are fascinating, precedent setting, and closely watched. Our conversation also includes a bit about the commercial agricultural chemical community.  Industry consolidation and international trade issues continue to challenge the commercial landscape, and they make keeping up with these issues all the more important. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW

Jul 2020

51 min 33 sec

This week I sat down with EPA Assistant Administrator Alexandra Dunn.  As many of our listeners know, Alex Dunn heads the Office of Chemical Safety and Pollution Prevention and is responsible for implementing the nation’s industrial and agricultural chemical laws, the Toxic Substances Control Act (TSCA) and the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), respectively. Alex has an extensive background in the environmental field and is a leading voice on TSCA and FIFRA.  Prior to Alex’s current role, she served as the Regional Administrator for EPA Region 1, and before Region 1, Alex served as the executive director and general counsel for the Environmental Council of States.  She has published extensively in the areas of the ethics of community advocacy, environmental justice, urban sustainability, water quality, cooperative federalism, the Clean Water Act, and more. Given Alex’s high profile role at EPA, we focused our discussion on implementation of the amendments to TSCA, which Congress enacted in 2016.  As we record this session, we are at the four-year anniversary of the new law, and we celebrate EPA’s many accomplishments in implementing the Congressionally mandated changes to the law.  As pollution prevention is an integral part of EPA’s mission, we also focus on initiatives under way to introduce safer and greener chemicals.  Finally, our discussion includes a look ahead to what is on EPA’s agenda for the remainder of the year, which promises to be extraordinarily busy. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW.

Jun 2020

30 min 8 sec

As we are now into June, Toxic Substances Control Act (TSCA) aficionados will be quick to note that “new TSCA” is now almost four years old.  Passage in June 2016 of the Frank R. Lautenberg Chemical Safety for the 21st Century Act occasioned EPA’s implementation of a law that has transformed industrial chemical regulation in the United States.  This week, to mark Lautenberg’s fourth birthday, I sat down with Dr. Richard E. Engler, B&C’s Director of Chemistry and all-around expert on all things TSCA, to look back on what EPA stakeholders have achieved over the past four years, and to look forward to what to expect the remainder of this year and beyond.  We address the progress EPA has made in reviewing new chemical innovations, regulating existing industrial chemicals, what early challenges have been resolved, and a few of the frustrations that linger.  As a 17-year veteran of EPA’s Office of Pollution Prevention and Toxics and now an extremely busy and tops in his field private consultant, Rich knows TSCA from both sides, and his insights are always spot on. Rich is a Ph.D. chemist who focuses here at B&C and our consulting affiliate, The Acta Group (Acta®), on all aspects of TSCA regulation and science policy.  In addition to his duties as a top chemist at EPA, Rich also headed EPA’s Green Chemistry Program.  Rich has reviewed more than 10,000 chemical notifications under TSCA and now is an indispensable part of our deep TSCA bench here at B&C and Acta. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW.

Jun 2020

46 min 6 sec

This week, as employees around the country are returning to their offices and work stations, I was excited to visit with Larry Sloan, CEO of the American Industrial Hygiene Association (AIHA), located here in the Washington, D.C., area. AIHA may not be a well-known organization to many of our listeners, but that could be about to change.  Founded in 1939, AIHA is a non-profit organization serving professionals dedicated to the identification, evaluation, control, and confirmation of environmental stressors in or arising from the workplace. Given AIHA’s extraordinary institutional expertise in workplace stressors, its role and prominence in getting workers back into a safe and healthful work environment in light of the COVID-19 pandemic has rocketed its Back to Work Safely initiative, one of the subjects of our fascinating conversation with Larry, into national prominence. Larry is a chemical engineer by training, and obtained an MBA from Northwestern’s Kellogg School of Management. Larry is a well-respected professional in Washington, D.C., chemical circles, with a distinguished career in trade association management. Prior to becoming CEO of AIHA in 2016, Larry was CEO of the Society of Chemical Manufacturers and Affiliates (SOCMA), an organization advancing the interests of specialty chemical manufacturers, and before joining SOCMA, Larry was President of the Adhesive and Sealant Council. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW. ©2020 Bergeson & Campbell, P.C.  All Rights Reserved

May 2020

45 min 42 sec

The question posed by this podcast may sound easy, but it is anything but. This podcast explores the fascinating yet commercially vexing jurisdictional divide between and among biostimulants, biopesticides, and fertilizers as each of these agricultural chemical products is vital to the agricultural community.  According to a recent U.S. Department of Agriculture report, the plant biostimulant industry alone is expected to be at least a $2.2 billion global market, swelling to $5 billion in 2025. As big as this market is, there is surprisingly a great deal of confusion in markets globally regarding what exactly is a biostimulant and how it differs from a fertilizer or a pesticide, and importantly how the U.S. Environmental Protection Agency (EPA) goes about regulating the claims made for these products.  This podcast focuses on these issues, especially as they relate to how EPA defines and regulates biostimulants, and offers some tips to stakeholders in this commercial space on how to avoid enforcement scrutiny. My guests today are my colleagues, Lisa Burchi and Sheryl Dolan.  Lisa is a resident in California and Of Counsel to B&C.  Lisa counsels clients on chemical law and regulation and has significant experience with legal and regulatory matters specifically related to these jurisdictional lines, which most often arise in the context of enforcement actions brought by EPA headquarters and regional offices. Sheryl Dolan is B&C’s Senior Regulatory Consultant.  Sheryl works with a wide variety of chemical innovators to commercialize their products and works closely with the legal team to make this happen.  Both Lisa and Sheryl are also employees of B&C’s consulting affiliate, The Acta Group, with offices here in D.C, Manchester, U.K., Brussels, Belgium, and Beijing, China. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW.

May 2020

44 min 49 sec

This week, I was thrilled to sit down with Richard Keigwin, Director of the Office of Pesticide Programs (OPP) at the U.S. Environmental Protection Agency (EPA) here in Washington, D.C.  As OPP Director, Rick leads the EPA office that reviews and approves pesticide products used to combat the spread of SARS-CoV-2, the virus that causes COVID-19.  Historically, OPP has consistently been one of the busiest offices in EPA’s Office of Chemical Safety and Pollution Prevention (OCSPP).  The pandemic has invited a virtual flood of interest in the next generation of antimicrobial pesticides to combat the virus’s spread, and Rick and his team have been navigating this flood and keeping their heads above water, as it were, from the safety of their own homes.  Rick takes us through what EPA is doing to accelerate the availability of new tools to combat the spread of the virus, how he has been orchestrating this massive effort from his remote office, and how he has been doing so while simultaneously addressing the usual heavy load of routine pesticide business during this pandemic. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW.

Apr 2020

34 min 21 sec

This week, I sat down with Eric Byer, President and CEO of the National Association of Chemical Distributors (NACD). Eric, like many of us these days, is working hard and under extraordinary circumstances ensuring that his member companies are able to continue to distribute much needed chemical products, including sanitizers and other cleaning products, in response to the pandemic.  Our conversation focused on these uniquely “in the moment” issues and a broad range of federal, state, and international issues on which NACD is focused, including extending the Chemical Facility Anti-Terrorism Standards (CFATS) program, TSCA implementation initiatives, and the impact of tariffs on imports from China on NACD member companies.  Eric is an amazing leader of an essential trade association, and our conversation provides insights into his success as President of NACD. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW.

Apr 2020

28 min 57 sec

This week, I sat down with Lisa Campbell, my business partner of many years and one of the nation’s foremost legal experts on the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). Given Lisa’s expertise, we engaged in a very timely discussion about the approval by the U.S. Environmental Protection Agency (EPA) of products under FIFRA to combat COVID-19, the disease caused by the coronavirus.  EPA has been deluged with applications to approve new products and/or new uses of existing products to combat the virus.  Lisa explains how antimicrobial pesticide products play an important role in public health and safety, the kinds of antimicrobial product categories regulated by EPA (including sanitizers, sterilants, disinfectants, and others), how approved products are deployed to combat the novel pathogen that causes COVID-19, and what EPA is doing to fast-track the approval process to get products out there to protect public health.  And as important as the federal EPA is in this regard, Lisa also explains the important role of state agencies in the pesticide product approval area.  We round out our discussion on EPA’s efforts, along with other federal law enforcement offices, to stop the proliferation of virus scams, most notably the sale and distribution of antimicrobial products falsely claiming to be effective against the spread of the coronavirus.

Apr 2020

24 min 46 sec

This week, I sat down with my colleague Karin Baron, a senior regulatory consultant here at B&C. In this conversation, Karin talks about recent European Union enforcement initiatives that have to do with the CLP legislation: Classification, Labeling, and Packaging legislation. Karin begins by telling us about the current state of harmonization along the lines of the GHS model, and how this might be more an aspiration than a reality. Then we talk about the history of the CLP legislation: how it was introduced, how it has changed over the years, and what recent changes are doing to bring it more in line with the GHS. We also go into a number of different themes that might be of interest to you, including why “mixture classifications” can be so varied across different regions and Karin gives some concrete recommendations and tips for manufacturers, distributors, and exporters that deal with the EU. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW.

Mar 2020

37 min 52 sec

This week, I sat down with my colleague, Dr. Richard Engler, Director of Chemistry here at B&C and The Acta Group (Acta®). We brought everyone up to date on the U.S. Environmental Protection Agency’s (EPA) implementation of the Toxic Substances Control Act (TSCA) fee rule and how it applies to entities obligated to pay a portion of the $1,350,000 per chemical fee for preparing an EPA-initiated risk evaluation, the legal and regulatory significance of the supplemental rulemaking on long-chain perfluoroalkyl carboxylate (LCPFAC) chemicals and the precedent it sets for eliminating the article exemption for imported articles containing these substances, and the significance of the recently updated TSCA Chemical Inventory with regard to the fast-approaching Chemical Data Reporting (CDR) cycle. As always, Rich is a font of information on these topics, and he does a great job of contextualizing this information for busy business people working in the chemical space. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW.

Mar 2020

28 min 2 sec

This week, I sat down with my colleague, Sheryl Dolan, a Senior Regulatory Consultant here at Bergeson & Campbell and The Acta Group.  As Sheryl’s practice focuses primarily on pesticide matters, we addressed a few hot topics captivating our interest.  Sheryl briefed us on the Environmental Protection Agency’s (EPA) Office of Pesticide Programs’ (OPP) forthcoming move from Crystal City, Virginia, to D.C. later this year, OPP’s recent deployment of its Emerging Pathogen Policy in light of the Coronavirus gripping the world, OPP’s continuing efforts to help define the jurisdictional divide between Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)-regulated pesticides and non-pesticide plant stimulants, enforcement initiatives in the pesticide area, and the fast approaching March 1 reporting deadline for pesticide establishments. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW.

Feb 2020

27 min 27 sec

This week, I sat down with my colleague, Dr. Richard Engler, Bergeson & Campbell’s Director of Chemistry, to discuss what the fuss is over EPA’s January 27, 2020, issuance of a “preliminary list” of companies responsible for the $1,350,000 per-chemical fee EPA charges to conduct a risk evaluation of a high-priority chemical under TSCA Section 6.  The scope of the entities “on the hook” is far broader than expected, and companies with little understanding of TSCA may be presumptively liable for these fees and TSCA enforcement scrutiny for failure to address the situation by March 27, 2020.  In our conversation, Rich explains how the fee rule works and discusses the reasons why industry was caught by surprise and unclear about how best to respond to the January notice.  Rich and I then explain why it is critically important for impact entities to begin now to think about forming a consortium to share the cost of the fees and related expenses and how B&C Consortia Management can assist. We also go into a number of different themes that might be of interest to you, including why the fee rule interpretation diverges from historical TSCA “carve-outs” for byproducts, impurities, and articles, and what companies can do to protect their interests. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW.

Feb 2020

24 min 54 sec

This week, I sat down with my colleagues Sheryl Lindros Dolan, Chris Bryant, and Dr. Richard Engler to discuss our fabulous 2020 Forecast, B&C’s and The Acta Group’s (Acta®) richly detailed overview of key trends in U.S. and global chemical law and policy. This 67-page document provides a comprehensive “one-stop” overview of global initiatives for the New Year of which stakeholders in the global chemical market must be aware. My colleagues provide a spirited overview of key developments, speculate on the impact of the U.S. general elections later this year, and muse generally about the shape of things to come with regard to all things chemical. 2020 may well be like no other election year, given all that is in the pipeline, statutorily mandated, and/or percolating at the state level. Download the 2020 Forecast here. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW.

Jan 2020

28 min 5 sec

This week, I sat down with my colleague Christopher Bryant, a Senior Regulatory Consultant here at Bergeson & Campbell. Chris has over 25 years of experience in environmental, health, and safety compliance, and, in particular, hazardous waste management and regulation under the Resource Conservation and Recovery Act (RCRA). I asked Chris to the studio to speak with me about RCRA:  what it is, how the law has developed, what is covered under it, and how we might expect -- or hope -- it to change for the better.  We discussed the history and stated goals of RCRA, and why, in our opinion, it has not lived up to some of its founding principles. Chris hits upon the subject of plastics and PFAS materials, and explains the evolution of EPA’s thinking about waste over the last few decades, including how RCRA has adapted to a business world that is becoming increasingly more sustainability-oriented.  We also talk about how other countries and regions manage hazardous waste regulation and how practices beyond RCRA can be influenced to achieve improved results. When it comes to hazardous waste and RCRA, Chris is simply the best, and it was great to sit down with him and pick his brain on this important topic.  So, here is my discussion with Chris Bryant about all things RCRA. ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW.

Dec 2019

54 min 58 sec

This week, I sat down with Jim Jones, Executive Vice President Strategic Alliances & Industry Relations at the HCPA, or Household & Commercial Products Association. Before moving into the private sector, as many of our listeners know, Jim served a long and very distinguished career with the U.S. Environmental Protection Agency in Washington, D.C. Jim began his career in the toxics office, specifically in pesticides, and eventually served as Assistant Administrator of the Office of Chemical Safety and Pollution Prevention in the Obama Administration. We talk about Jim’s extraordinary background and how it prepared him for the task of helping to modernize the Toxic Substances Control Act in passing the Lautenberg Act amending TSCA in 2016. Jim takes us back to the summer of 2016 and paints a picture of what it felt like to watch with anticipation as the political proceedings surrounding the amendment unfolded. In addition to talking about TSCA’s recent history and EPA’s implementation of it, Jim shares career advice, tips for other industry groups, and first-hand experiences about the difference between the private and public sectors of this industry. Jim has a wealth of knowledge and experience, and I am excited to share my conversation with him with you. So, here is my discussion with Jim Jones about his experiences leading up to passage of the Lautenberg Act… ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW.

Nov 2019

40 min 42 sec

This week, I moderated a spirited discussion with two members of the B&C team:  Sheryl Dolan, a senior regulatory consultant who specializes in agricultural and biocidal chemical product registration and defense, and Dr. Richard Engler, our Director of Chemistry and a 17-year-veteran of EPA.  Both Sheryl and Rich are expert in marshaling new product chemical technologies through the gauntlet of federal, state, and international chemical product approval. Throughout our discussion, Sheryl and Rich walk us through what it takes to bring a new technology to EPA (or any other regulatory authority) and to help the regulators understand the benefits and safety of the new technology, especially when dealing with older regulatory frameworks that are sometimes ill-suited to anticipate the challenges posed by cutting edge technologies.  We talk about the regulatory challenges that the developer of a new product is likely to face, and how our team recommends preparing for these often make or break challenges.  We also get into a bit of the history of TSCA and FIFRA, the impact that public opinion and transparency can have on the regulation process, and how regulatory systems are informed of and respond to technological change. There is a lot to unpack in this discussion for anyone with an interest in the regulatory process, whether you are planning on bringing an innovative product to market or enhancing a new aspect of an existing product.  It was great having Sheryl and Rich in the studio to walk me through some of this, and I am excited to share it with you.  So, here is my discussion with Sheryl Dolan and Dr. Rich Engler about new technologies and their regulatory processes… ALL MATERIALS IN THIS PODCAST ARE PROVIDED SOLELY FOR INFORMATIONAL  AND ENTERTAINMENT PURPOSES. THE MATERIALS ARE NOT INTENDED TO CONSTITUTE LEGAL ADVICE OR THE PROVISION OF LEGAL SERVICES. ALL LEGAL QUESTIONS SHOULD BE ANSWERED DIRECTLY BY A LICENSED ATTORNEY PRACTICING IN THE APPLICABLE AREA OF LAW.

Oct 2019

46 min 8 sec