Richard Engler

Director of Chemistry

Richard E. Engler, Ph.D. is Director of Chemistry with Bergeson & Campbell, P.C. (B&C®). Dr. Engler is a 17-year veteran of the U.S. Environmental Protection Agency (EPA) and is one of the most widely recognized experts in the field of green chemistry, having served as senior staff scientist in EPA’s Office of Pollution Prevention and Toxics (OPPT) and leader of EPA’s Green Chemistry Program. He has participated in thousands of Toxic Substances Control Act (TSCA) substance reviews at EPA, as well as pre-notice and post-review meetings with submitters to resolve complex or difficult cases, and he draws upon this invaluable experience to assist B&C clients as they develop and commercialize novel chemistries.

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.