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

July 1994

Citation: 24 ELR 10357

Issue: 7

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

Editors' Summary: In this final installment of a three-part Article, the authors complete their detailed examination of the TSCA statute and regulatory program. The authors begin the installment by discussing TSCA §§ 6 and 7's regulation of existing chemicals, including asbestos, PCPs, and imminently hazardous materials. The authors stress the important potential ramifications of the 5th Circuit's Corrosion Proof Fittings decision. The authors next examine TSCA § 8's reporting and recordkeeping requirements and, then, review the import certification and export notification requirements of TSCA §§ 13 and 12(b). Finally, the authors address civil and criminal enforcement under TSCA §§ 15 and 16.

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. The authors thank Ann Claassen for her assistance in drafting portions of this Article addressing TSCA §§ 6(e) and 8.

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