TSCA Reform Is Real: EPA Publishes Its "First Year Implementation Plan"

On Wednesday, EPA released its “First Year Implementation Plan” for the recently enacted TSCA reform legislation.

Before getting to the details, it's worth emphasizing what a significant accomplishment it was to get TSCA reform passed in the current Congress. It's also enlightening, because the message of TSCA reform may be that reform of existing legislation is possible, but only if the existing legislation is so obviously broken that it harms everyone. TSCA was ripe for amendment because not only was it not working, but it was a negative sum game: it was bad for business and it was bad for the environment. I'm not sure it provides much of a model for efforts to amend the Clean Air Act to address climate change or the Clean Water Act to figure out what a "water of the United States" is.