May 20, 2014
On May 9, 2014, the U.S. EPA issued a pre-publication copy of an Advance Notice of Proposed Rulemaking (ANPR) requesting public comment on regulatory and voluntary mechanisms for obtaining information on chemical substances and mixtures used in hydraulic fracturing (HF) operations. EPA intends to rely for this purpose upon its Toxic Substances Control Act (TSCA) authority – namely, TSCA Section 8(a), which authorizes EPA to require chemical manufacturers and processors to maintain records and submit information to the Agency, and TSCA Section 8(d), which authorizes EPA to require the submission of health and safety studies from chemical manufacturers, processors, and distributors.
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Davis Graham & Stubbs LLP, one of the Rocky Mountain region’s preeminent law firms, serves clients nationally and internationally, with a strong focus on corporate finance and governance, mergers and acquisitions, natural resources, environmental law, real estate, and complex litigation. Our lawyers have extensive experience working with companies in the energy, mining, technology, hospitality, private equity, manufacturing, asset management, and aviation industries. As the exclusive member firm in Colorado for Lex Mundi, the world’s leading network of independent law firms, DGS has access to in-depth experience in 100+ countries worldwide.