Mr. Green is skilled in translating complex business and technical issues into effective advocacy and in counseling on matters involving regulatory development, compliance and enforcement. He is experienced with the range of federal environmental laws and state regulatory programs, as well as with European Union and international requirements, and he has particular knowledge in the area of chemicals and toxic substances regulation. He also provides counsel regarding the safety of consumer products.
Specific issues on which Mr. Green counsels clients include the registration and marketing of antimicrobial pesticide products under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA); chemical and product regulation under the Toxic Substances Control Act (TSCA), and the European Union’s Restriction of Hazardous Substances (RoHS) directives and Registration, Evaluation, and Authorization of Chemicals (REACH) legislation; and the regulation of hazardous air pollutants under the Clean Air Act, including the development of emission standards for major and area sources. Mr. Green also assists clients with TSCA and Toxic Release Inventory (TRI) reporting; Clean Water Act effluent limitations guidelines (ELGs); Resource Conservation and Recovery Act (RCRA) hazardous waste determinations and corrective action; and Spill Prevention and Control and Countermeasure (SPCC) compliance.
Representative Experience
Obtained groundbreaking "public health" registration for Antimicrobial Copper Alloys under EPA's FIFRA program.Developed strategies for compliance with the European Union's REACH requirements for numerous industry sectors.
Organized the Manganese Interest Group to address development of revised health standards for manganese.
Persuaded the Environmental Protection Agency (EPA) to rescind guidance that would have required TRI reporting for the chemicals in steelmaking slag sold for use as a product.
Secured for the industrial laundry industry issuance of the first-ever final EPA "no regulation" rule after ELGs had been proposed.
Represented the iron and steel industry in convincing the EPA to scale back proposed ELG revisions, resulting in capital cost savings of over $1 billion. Persuaded the National Toxicology Program (NTP) to not list "nickel alloys" as carcinogens, and to change the listing for chromium to identify only specific chromium compounds.
