Environmental Law: A New Formula For Chemical Regulation?

Title I of the Toxic Substances Control Act (TSCA) sets forth the process through which "new" chemical substances are introduced into commerce, and provides for testing and evaluation of existing chemical substances under certain circumstances. TSCA's general chemical regulatory framework is criticized by the environmental community for "grandfathering" existing chemical substances without testing, and for requiring that the Environmental Protection Agency clear high hurdles before taking action with respect to existing chemical substances.

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