EPA Plans New Rulemaking for PBTs , Extends Compliance Dates for PIP (3:1) Rule – Update from Bergeson & Campbell, P.C.

The U.S. Environmental Protection Agency (EPA) announced on September 3, 2021, that it intends to initiate a new rulemaking and anticipates proposing new rules for five persistent, bioaccumulative, and toxic (PBT) chemicals that are the subject of final risk management rules under the Toxic Substances Control Act (TSCA). Additionally, and importantly, EPA is extending the compliance dates for the prohibitions on processing and distribution and the associated recordkeeping requirements of one of these PBT chemicals, phenol, isopropylated phosphate (3:1) (PIP (3:1)). The action is imperative as the current No Action Assurance (NAA) was set to lapse tomorrow at 11:59 p.m.  For more information on EPA’s announcement, please read the full memorandum.


2200 Pennsylvania Ave., N.W.
Suite 100W
Washington, D.C. 20037
(202) 557-3800
(202) 557-3836 (fax)