Private Enforcement Options Under TSCA

Interplay between Private Enforcement Options Under TSCA 

It is not uncommon for activists to proceed on both fronts with respect to issues of interest. For example, challenges to the voluntary High Production Volume (HPV) Challenge Program were initiated under both 20 and 21. On December 27, 1999, People for the Ethical Treatment of Animals (PET A) on its own behalf and on behalf of four other organizations, including Physicians Committee for Responsible Medicine, filed a citizens petition 

For an excellent discussion on the interpretation of the standards of Judicial review under TSCA 20 and 21, see Environmental Defense Fund v. Reilly, 909 F.2d 1497, 1501-1509 (D.C. Cir. 1990). 

TSCA i 21(b)(5) says The remedies under this section shall be in addition to, and not in lieu of, other remedies provided by law. 

The collaborative nature of the HPV Challenge Program encouraged the formation of consortia to share data on a global basis.  

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C. Interplay between Private Enforcement Options Under TSCA... 

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