Cynthia AM
Stroman
(Cynthia)

Assisting product manufacturers and importers with TSCA compliance and enforcement matters, including Section 6 risk evaluations under the Lautenberg Chemical Safety for the 21st Century Act.

Counseling manufacturers and distributors on FIFRA pesticide registration requirements, exemptions, and emerging pathogen claims for antimicrobial disinfectants, treated articles, and cleaning products.

Advising manufacturers and importers on TSCA significant new use rules (SNURs), new chemicals submittals, import/export certifications, reporting and enforcement issues under the Chemical Data Reporting (CDR) program, coordinating multiple submissions of product assessment studies to EPA under TSCA section 8(e), and counseling on applicability of protections for confidential business information (CBI).

Counseling multinational clients on materials compliance management system design and auditing, and product stewardship program management.

Counseling product manufacturers on warnings and “no significant risk level” requirements under California’s Proposition 65, advising companies regarding private party enforcement, and assessing adequacy of Proposition 65 support documentation for proposed listing of chemicals as carcinogens or reproductive hazards.

Advising clients nationwide on the safe transportation of hazardous materials (“hazmat”) across all modes, including highway, rail, aviation, marine and pipeline, under the Hazardous Materials and Pipeline Safety regulations of the Department of Transportation (DOT) and the Federal Aviation Administration (FAA), as well as related international transportation of dangerous goods regimes (IATA, IMDG).

Advising developers or other project participants on NEPA, Clean Air Act, Endangered Species Act, Marine Mammal Protection Act and other environmental, health and safety (EHS) considerations associated with natural gas projects, petrochemical facilities, LNG terminals, renewable energy facilities and pipelines.

Assisting clients with EHS issues in domestic and international transactions, including those involving natural gas production and transportation, LNG, petrochemicals, shale oil and gas, liquids terminals, chemicals, electrical power generation, as well as wind, solar, storage and other renewable energy assets.

Advising clients on PHMSA regulation of pipelines, including reactivation and abandonment, product changes, classification of hazardous liquids, and incident regulation.

Counseling clients on the regulatory status of potentially hazardous materials, including specific packaging and labeling requirements, under RCRA, DOT, OSHA and GHS and other international regimes, including EHS issues applicable to both hazardous and non-hazardous materials.

Providing strategic advice on EHS regulation of offshore facilities, particularly concerning the intersection of EHS statutes and the Outer Continental Shelf Lands Act.

Representing and advising stakeholders in Magnuson-Stevens Act, NEPA, and other administrative proceedings regarding fisheries, protected species and related issues.

Working with clients on hazardous and solid waste management issues, including negotiating remediation contract provisions; assessing hazardous waste liability for product residuals, recyclables, and other materials; and evaluating waste management compliance and product stewardship programs.

Preparing expert witnesses in a number of scientific disciplines, including emissions testing and modeling, analytical chemistry, toxicology, epidemiology, industrial hygiene, hazard communications, product warnings, process engineering and chemistry; and preparing scientific and regulatory content in cases involving alleged exposures to PFAS, arsenic, beryllium, manganese, benzene, radioactive materials (including NORM), criteria pollutants, silica, PCBs, dioxins, furans, solvents, chlorinated hydrocarbons and various other substances.

Developing successful Daubert challenges to testimony of plaintiffs’ experts, achieving exclusion or narrowing of such experts’ testimony; and preparing trial cross-examination of plaintiffs’ experts.

Working with scientific experts on human health and ecological risk assessments in administrative proceedings and litigation, including developing and evaluating risk assessments, product stewardship strategies and scientific manuscripts in anticipation of litigation or regulatory proceedings.