Lynn Bergeson

Managing Partner

Lynn L. Bergeson, Managing Partner of Bergeson & Campbell, P.C. (B&C®), has earned an international reputation for her deep and expansive understanding of the Toxic Substances Control Act (TSCA), the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), the European Union Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) regulation, and especially how these regulatory programs pertain to nanotechnology, industrial biotechnology, synthetic biology, and other emerging transformative technologies. Her knowledge of and involvement in the policy process allow her to develop client-focused strategies whether advocating before Congress, the U.S. Environmental Protection Agency (EPA), the U.S. Food and Drug Administration (FDA), or other governance and standard-setting bodies.

8:30 - 10:00 am

Friday May 10, 2024

Scientific Affairs Committee and Task Force Meeting

PFAS Reporting’s Silver Linings Playbook: Developing a Strategic Approach to Managing Global Reporting Obligations

The TSCA Section 8(a)(7) reporting obligation is a wake-up call for many businesses. It boldly forces a commercial reckoning that PFAS are indeed ubiquitous and embedded in many more products and applications than realized. This hard truth raises many commercial, legal, and logistical issues, almost all of which are unwelcome. If there is a silver lining, it is that the TSCA obligation presents an opportunity to be strategic, efficient, and forward looking in managing PFAS in the supply chain. The TSCA obligation is one of many. The EU proposal to restrict PFAS under REACH, with certain use-specific exemptions, reflects a growing international trend. States are also extremely active in regulating PFAS, sometimes introducing requirements that are commercially challenging to meet. This session will review key legal and practical issues that have emerged regarding the TSCA reporting obligation for PFAS and will contextualize this “one and done” report within a broader framework of emerging international, federal, and state PFAS restrictions so that product stewards and regulatory managers are equipped to develop a comprehensive playbook for PFAS reporting obligations.