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Warren Lehrenbaum

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Retailers need to prepare for a major shift in chemical regulation policy recently announced by the U.S. Environmental Protection Agency (EPA) that could affect a broad range of products currently being sold in the US. Under this sweeping new policy, EPA plans to address chemical risks by directly regulating articles that are manufactured with those chemicals. Crowell environmental attorneys, Warren Lehrenbaum and Jennifer Giblin, addressed this and other important developments at EPA in a wide-ranging question and answer session with the Retail Industry Leaders Association on Tuesday, October 5, 2021.
Continue Reading EPA’s Shift In Chemical and Hazardous Materials Regulation and What Retailers Can Expect

Two important developments from the Environmental Protection Agency (EPA) are potentially significant to the retail industry, but may have escaped widespread attention in light of recent worldwide events. Somewhat unusually, both proposals are administered by EPA under TSCA, despite the fact that TSCA typically applies to chemical products, not manufactured articles.

Comment and compliance deadlines…

EPA has proposed a new rule to restrict the use of seven toluene diisocyanates (TDIs) in consumer products.  TDIs are commonly used in the production of polyurethanes found in foams, coatings, elastomers, adhesives and sealants used in consumer products.  Flexible foams (for cushioning) and rigid foams (for insulation) are the chief uses for TDI.

Published…

Retailers face serious challenges in complying with their obligations under Resource Conservation and Recovery Act (“RCRA”) and other federal environmental statutes in light of the wide variety of retail products covered by EPA’s waste disposal regulations. EPA recently expressed its intent to consider future rulemaking under RCRA governing retail products unsold, returned, or removed from…