Greg Clark counsels clients on regulatory and environmental issues, focusing on the Toxic Substances Control Act (TSCA), the Clean Air Act (CAA), state volatile organic compound (VOC) regulations, the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), the Clean Water Act (CWA), and the Resource Conservation and Recovery Act (RCRA).
Greg assists clients needing approval of new chemical substances, genetically modified organisms (GMOs), and pesticides under TSCA, FIFRA, and similar laws abroad. Clients value his extensive experience guiding them through the Premanufacture Notification (PMN), Low Volume Exemption, Microbial Commercial Activity Notice (MCAN), and TSCA Environmental Release Application (TERA) review processes. He also assists clients by negotiating the terms and conditions of TSCA Section 5(e) consent orders and Significant New Use Rules (SNURs). Additionally, Greg advises companies seeking to market biotechnology-derived products and their production platforms (including bacteria, yeast, algae, and plants) while navigating the complex regulatory requirements administered by the U.S. Environmental Protection Agency (EPA), the U.S. Food and Drug Administration (FDA), and the Animal and Plant Health Inspection Service (APHIS).
Greg’s extensive background enables him to provide guidance to companies and trade associations on the prioritization, risk evaluation, and risk management of existing chemicals, including chemicals on the 2014 TSCA Work Plan, following the Lautenberg Act amendments to TSCA. Through this work, he develops detailed comments and regularly interacts with EPA staff. He assists companies with periodic reporting under the TSCA Chemical Data Reporting Rule and other agency reporting programs. He also designs, conducts, and coordinates comprehensive internal audits of TSCA compliance for existing operations under EPA’s “Audit Policy,” as well as under other penalty mitigation policies.
Greg has in-depth knowledge representing clients in CAA rulemakings and enforcement matters before administrative agencies, including drafting highly technical comments, filing petitions for reconsideration and judicial review, and meeting with agency staff.
Greg has a background in molecular biology and emergency preparedness, offering him a unique foundation from which to advise his clients and assist the firm.
More Legal and Business Bylines From Gregory A. Clark
- EPA Defers March 9 TSCA Ban on Articles Containing PIP (3:1) by 180 Days; Reopens Comment Period on All Five Final PBT Rules for Full Reconsideration - (Posted On Tuesday, March 09, 2021)
- EPA Proposes Changes to TSCA Fee Rule - (Posted On Thursday, January 14, 2021)
- EPA Releases Fall 2020 Regulatory Agenda, Forecasting a Busy Year Ahead for TSCA - (Posted On Wednesday, December 16, 2020)
- TSCA CDR Deadline Extended to January 29, 2021 - (Posted On Wednesday, November 25, 2020)
- Final EPA Guidance Procedures Effective November 18, 2020 - (Posted On Monday, November 02, 2020)
- EPA Proposes Landmark Rule Setting General Requirements and Procedures for Guidance Documents - (Posted On Tuesday, May 26, 2020)
- COVID-19 Unsympathetic to TSCA Compliance - (Posted On Thursday, April 09, 2020)
- EPA Relaxes TSCA Fee Self-Identification Requirement - (Posted On Thursday, March 26, 2020)
- Deadline Approaching for 2018 CARB Survey - (Posted On Tuesday, February 11, 2020)
- California Considering Further Restrictions on VOCs in Consumer Products - (Posted On Monday, November 25, 2019)