December 7, 2021

Volume XI, Number 341

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December 07, 2021

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December 06, 2021

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ECHA Posts New Set of Q&As for Downstream Users of Nanoforms

The European Chemicals Agency (ECHA) has posted a new set of questions and answers (Q&A) for downstream users of nanoforms. The new Q&As, posted under Section I, include:

  • What are my obligations as a downstream user purchasing, modifying or creating nanoforms?

  • How do I know when I have created a new nanoform from a supplied substance?

  • How do I know whether the nanoform I have created is covered by my supplier if I received [a safety data sheet (SDS)] with an exposure scenario attached?

  • How do I know whether the nanoform I have created is covered by my supplier if: i) I did not receive an SDS or ii) I received an SDS but it does not contain exposure scenarios?

  • How to check if my use and the conditions of use are covered by the exposure scenario received?

  • What do I need to do if my nanoform/uses are not covered by my supplier?

  • What should the downstream user chemical safety report contain?

  • How do I report to ECHA that I have performed a downstream user chemical safety report (or I am relying on an exemption)?

©2021 Bergeson & Campbell, P.C.National Law Review, Volume XI, Number 282
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About this Author

Lynn Bergeson, Campbell PC, Toxic Substances Control Act Attorney, federal insecticide lawyer, industrial biotechnology legal counsel, Food Drug Administration law
Managing Partner

Lynn L. Bergeson 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), European Union Registration, Evaluation, Authorization and Restriction of Chemicals (REACH), 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 allows her to develop client-focused strategies whether...

202-557-3801
Carla Hutto, Bergeson Campbell PC environmental law regulatory analyst,Toxic Substances Control Act law attorney
Regulatory Analyst

Since 1996, Carla Hutton has monitored, researched, and written about regulatory and legislative issues that may potentially affect Bergeson & Campbell, P.C. (B&C®) clients. She is responsible for creating a number of monthly and quarterly regulatory updates for B&C's clients, as well as other documents, such as chemical-specific global assessments of regulatory developments and trends. She authors memoranda for B&C clients on regulatory and legislative developments, providing information that is focused, timely and applicable to client...

202-557-3809
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