The recently enacted sweeping revisions to the Toxic Substances Control Act (TSCA) have been decades in the making, but the EPA needed to begin implementing the changes even before the ink of President Obama’s signature dried. Accordingly, just 1 week after enactment, the Agency released its First Year Implementation Plan for the new law, including several actions under the heading “Beginning on Day 1.”
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TSCA reform would not have occurred without the encouragement and infusion of ideas from many stakeholders within both government and the private sector. At this juncture, the EPA seems to recognize that that level of support should be reciprocated with transparency from the Agency on how it intends to proceed.