Representative Matters

  • Petrochemicals. Assisted a major petrochemical company in evaluating the applicable U.S. federal and state requirements for handling controlled substances and precursors at its laboratories around the country, and in developing strategies for ensuring compliance, including contracting with a third party for certain compliance obligations.
  • Pesticides. Assisted clients in meeting federal and state requirements for obtaining pesticide registrations and related seed permits or deregulations, and advised them on the full range of compliance issues, including label language (and its potential impact on product liability); import and export restrictions; supply, manufacturing, licensing, and marketing relationships and contracts for both pesticides and related seed matters; and allowable label and marketing claims for both agricultural and consumer products, including antimicrobial claims.
  • Controlled Substances. Represented a group of more than 300 research-based and generic pharmaceutical companies on emerging pharmaceutical product take-back laws. Assisted with the preparation of early organizational documents and formal bylaws that addressed membership criteria and dues, voting structure, board of directors, committees, limitations of liability, and data confidentiality. Prepared vendor contracts, product stewardship plans (including protocols addressing applicable DEA and other requirements), and other regulatory submissions.
  • Products. Defended chemical companies in civil enforcement actions brought by federal and state agencies and by citizens under the Clean Air Act (including new source review and various NESHAPs and NSPSs), the Clean Water Act, the Toxic Substances Control Act (TSCA); the Emergency Planning and Community Right-to-Know Act (EPCRA), and the Resource Conservation and Recovery Act (RCRA).
  • International. Represented the U.S. chemical industry in numerous international negotiations concerning international controls on chemical use and production, including the UNEP POPs Convention, the Rotterdam PIC Convention and initiatives in Europe and North America targeting persistent, bioaccumulative, and toxic chemicals (PBTs).