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With over 32 years of experience at the U.S. Environmental Protection Agency in the application and integration of legal requirements, policy drivers, and scientific understanding concerning the assessment and regulation of chemicals, nanoscale materials, and intergeneric microorganisms, Charlie Auer brings a sophisticated and in-depth understanding of:

  • regulatory requirements for and technical/science policy issues relating to reporting, testing, assessment, and management of new and existing chemicals under TSCA;
  • applied approaches to and strategies for chemical testing, assessment, and management;
  • developing options for and commenting/responding to legislation regarding TSCA reform;
  • strategies and approaches to develop, inform, and apply green chemistry/Design for the Environment solutions to guide substitution decisions and to “green” corporate product lines; and
  • statutory, rulemaking, and regulatory requirements, chemical policy issues, and strategies under chemical control laws in the U.S. and major trading partners, and under multilateral environmental agreements. 

As a consultant, he can provide clients with policy and technical analysis and with expert advice and insights on new chemicals notification and regulation, chemical testing, information reporting, assessment, management, and compliance issues and needs. He has earned the respect of diverse stakeholder groups (industry, environmentalists, States, Tribes, etc.), both domestically and internationally, and can be an effective interlocutor in efforts to find effective and feasible common ground solutions which meet the needs of the client as well as those of the other stakeholders.

Specific areas where his expertise could be used to meet the needs of clients include:

  • the application and interpretation of regulatory requirements under the Toxic Substances Control Act (TSCA), including notice and comment rulemaking, negotiation of enforceable orders, and regulatory compliance under, inter alia, §4 testing (test rules and ECAs),  §5 new chemicals (PMNs, §5(h)(4) exemptions, §5(e) orders, and notices on nanoscale materials and MCANs/TERAs on intergeneric microorganisms), §5(a)(2) Significant New Use Rules (SNURs), §5(b)(4) "chemicals of concern" listings, §6 control actions, §8 reporting (Inventory Update Rule, §8(e) "substantial risk" notices), and §12(b) export notices;
  • implementation of ongoing voluntary programs such as the HPV Challenge, Nanoscale Materials Stewardship Program, PFOA 2010/2015 Stewardship Program, etc.;
  • reviewing and responding to EPA chemical Action Plans or other chemical hazard/risk assessments on new or existing chemicals, nanoscale materials, or intergeneric microorganisms;
  • the development and implementation by EPA of future regulatory requirements and voluntary programs;
  • the development and analysis of future statutory approaches to chemicals in the U.S., including identification/analysis of issues and strategies and consideration of possible policy objectives, statutory requirements, information reporting schemes, regulatory standards, etc.;
  • reviewing and responding to State initiatives or requirements on chemicals and pollution prevention;
  • reviewing and applying assessment procedures such as Structure Activity Relationships (SAR) analysis to inform assessments on new chemicals and identify/develop safer substitutes/Design for the Environment alternatives;
  • developing and applying approaches such as green chemistry, pollution prevention, Design for the Environment, and safer substitutes solutions to solve specific environmental problems or to meet corporate green/sustainability commitments/needs;
  • providing review of and advice on meeting product stewardship and other corporate responsibility approaches, including strategies for sustainability or approaches to meeting the needs of retailers and downstream users; and
  • reviewing and providing technical and regulatory advice concerning foreign national and international environmental protection issues and activities, including those relevant to foreign regulatory schemes and approaches (Canadian CMP under CEPA, EU REACH, Japan, China, Mexico, etc.), multilateral environmental agreements (Stockholm and Rotterdam Conventions, LRTAP POPs) and policy instruments (SAICM/Dubai Declaration, UNEP Global Mercury Program), and multilateral fora (OECD EHS, CEC Sound Management of Chemicals (SMOC), UNEP, etc.). 
Charles Auer & Associates, LLC can be reached at auer.charlesm@gmail.com or by phone at 301-525-3467.
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