3E EH&S Expressions Blog

3E EH&S Expressions is our forum for sharing our latest musings and observations on the ever-evolving EH&S regulatory compliance landscape. Here we will be introducing you to some of 3E’s most prolific and valued subject matter specialists weighing in on some of the more complex and time-consuming issues affecting our industry today, including TSCA Reform, REACH, GHS, Conflict Minerals and more.

July 14, 2016James Lee

This blog post has been updated since its original publication. Summary On 7 July 2016, the U.S. Senate voted 63-30 to approve a genetically modified organisms (GMO) bill (S. 764) that, if enacted, would preempt state GMO labeling laws by making it a federal requirement that food companies label their...

June 29, 20163E Global Research Team

The historic referendum vote on 23 June 2016 by the public in the United Kingdom (UK) (which includes England, Scotland, Wales, Northern Ireland, and Gibraltar) on whether the UK should remain in the European Union (EU), otherwise known as “Brexit,” has sparked many concerns in businesses operating in Europe and the UK. The future of many political, trade and commerce issues between the UK and the EU will remain unsettled until the former’s formal initiation of Article 50 procedures under the Treaty on European Union (“Withdrawal of a Member State from the EU”) and the related negotiations. However, it is clear now that if Brexit does occur – and the UK does leave the EU – companies, especially importers of chemicals and chemical products, must have a proactive strategy to handle the commerce and regulatory impacts of the UK's departure from the EU.

June 29, 2016Bernie Henn

On June 20, 2016, the European Chemical Agency (ECHA) added one new Substances of Very High Concern (SVHC) to the REACH Candidate List for Authorization. The new substance added is called: Benzo[def]chrysene also called benzo[a]pyrene also called (carcinogenic, mutagenic, toxic for reproduction, PBT, and vPvB) and is a polycyclic aromatic...

June 17, 2016Kirsten Wallerstedt

On 16 June 2016, the European Union (EU) Commission, the Parliament and the Council reached an agreement on conflict minerals. EU firms importing tin, tungsten, tantalum, gold and their ores (3TG), including processed metals, will be required to do due diligence checks on their suppliers. The aim is to stop trade in 3TG which funds conflicts and human rights abuses around the world. The Commission will also develop incentives and voluntary supply chain due diligence reporting tools for downstream EU companies that use these metals and minerals as components in their products.

June 9, 2016

Editor's Note: The original artcle has been updated since June 9, 2016. On 22 June 2016, U.S. President Barack Obama signed the Frank R. Lautenberg Chemical Safety for the 21st Century Act (H.R. 2576) which modernizes the 40- year-old Toxic Substances Control Act (TSCA).

May 13, 2016Bernie Henn

Significantly, HARPC has changed allergen control through the Good Manufacturing Practices (GMP) revisions. In fact, over 25 allergen related GMP mentions can be found in HARPC. Recommendations have been replaced with required GMPs under the HARPC rule. Allergen cross-contact must be mentioned in the GMP’s. Allergen controls must also address handling, storage and use.

May 12, 2016Bernie Henn

FSMA is changing how companies manage undeclared allergen risk during the production of finished products. For example, raw agricultural commodities are exempt from FALCPA. That does not mean there is not still a risk that a commodity ingredient contains an undeclared and unexpected allergen such as a peanut protein. Food fraud can also be an allergen source. An example of food fraud is an undocumented substitution of a cheaper peanut protein for an almond protein.

May 10, 2016Bernie Henn

The Food Safety Modernization Act (FSMA) has posed significant changes in the food industry, with specific changes to allergen controls and good manufacturing practices (GMPs). Having GMPs for allergen control is no longer just a company best practice but a requirement of companies under FSMA.

February 23, 2016Bernie Henn

On December 17, 2015, the European Chemical Agency (ECHA) added five new Substances of Very High Concern (SVHC) to the Candidate List for Authorization.

December 22, 2015James Lee

In the evening of 17 December 2015, the U.S. Senate passed the “Frank R. Lautenberg Chemical Safety for the 21st Century Act” (S. 697), which reforms the Toxic Substances Control Act (TSCA) for the first time since its enactment in 1976. The Senate approved the legislation by unanimous consent in a voice vote and broke its months-long deadlock on the floor vote. The language of the passed bill is an updated version of S. 697 from October. Sponsored by Senators David Vitter (R-LA) and Tom Udall (D-NM), S. 697 has gained filibuster-proof support this year. The next phase of the legislative process is a conference committee to reconcile the differences in the House and Senate versions of TSCA reform.