TSCA Reform: Suggestions for Workable, Effective Change
(August 2010; 42 pages) Charles M. Auer, former director of the
Environmental Protection Agency's Office of Pollution Prevention
and Toxics, along with Blake A. Biles and Lawrence E. Culleen, who
also served in leadership roles at EPA in implementing the Toxic
Substances Control Act, suggest how to strengthen the law. Auer
also is joined by Lynn L. Bergeson and Lisa R. Burchi of Bergeson
& Campbell PC in evaluating EPA's efforts to create a
"chemicals of concern" list.