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A Practitioner's Guide to the Toxic Substances Control Act: Part II

June 1994

Citation: 24 ELR 10285

Issue: 6

Author: Carolyne R. Hathaway, David J. Hayes and William K. Rawson

Editors' Summary: In this second installment of a three-part Article, the authors continue a detailed examination of the TSCA statute and regulatory program. They begin the installment with a review of TSCA § 5(e) orders and consent orders and significant new use rules. They next discuss imposition of requirements to conduct health and environmental effects testing on chemical manufacturers and processors, summarizing TSCA § 4's statutory authority and EPA's regulatory program. They conclude this installment with a discussion of exemptions from test rules, cost reimbursement provisions, and judicial review.

Carolyne R. Hathaway is a senior environmental associate in the Washington, D.C., office of the national law firm of Latham & Watkins. David J. Hayes is a partner at Latham & Watkins and chairs the Environmental Department of the firm's Washington, D.C., office. He also chairs the Board of Directors of the Environmental Law Institute. William K. Rawson is an environmental partner in Latham & Watkins' Washington, D.C., office.

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