Who We Are

Biobased and Renewable Products Advocacy Group (BRAG®)

Borrowing from William Shakespeare….WHAT’S IN A NAME?  That which we call a biobased chemical. By any other name would stand as sustainable. And yet, it is the mere name of the biobased chemical that hinders its ability to go to market! 

Did you know that the Toxic Substances Control Act (TSCA) is interpreted and applied in ways that often cause new biobased chemicals and their derivatives to be subject to stringent premarket review by the U.S. Environmental Protection Agency (EPA)?  This review often results in the application of restrictions that are not applicable to older chemical substances already in commerce.  This lack of consistency results in regulatory and commercial challenges for new biobased chemical products that hamper commercialization pathways and invite considerable delays to market entry.

This oddity of the current EPA naming system results in newer biobased technologies that offer the same, if not greater, benefits than existing chemicals now being commercialized.  Any company or organization intending to market biobased products -- whether they come from plants, algae, or industrial waste -- should be aware of this situation and join the effort to create a more sensible regulatory approach. 

BRAG is a group of international and well respected member organizations and companies engaged in the development of biobased or renewable chemical products.  BRAG members recognize the importance of advocacy, education, and communication.

BRAG is helping its members understand and comply with the application of TSCA to their products and operations, educating regulatory officials on biobased chemical production and the application of TSCA to these products, and developing strong and compelling advocacy platforms to ensure the robust commercialization and growth of biobased and renewable chemical feedstocks.  No other biobased chemical industry consortium focuses on TSCA in this way or on biobased chemical commercialization and associated regulatory inequities.  Because BRAG is managed by B&C® Consortia Management, L.L.C. (BCCM), a group that has regulatory compliance advisors, legal counsel, and science policy experts available for consultation and strategy development, we have the legal, technical, and management capacity to identify, develop, and implement successfully strategic plans to modify current EPA approaches or policies.

Our People

Kathleen Roberts, Executive Director of BRAG, is a recognized expert in chemical control regulation under TSCA and the unique and somewhat complicated ways in which these rules apply to biobased and renewable chemicals and their derivatives, with over 25 years' experience in engaged advocacy, compliance, and communication activities with industry and EPA staff. Ms. Roberts writes and speaks frequently about the regulation of renewable chemicals.

Ms. Roberts' articles have appeared in The Environmental Forum, Industrial Biotechnology, Law 360, and Biofuels Digest, among other publications. She has presented numerous TSCA workshops and seminars, including at the Advanced Bioeconomy Leadership Conference, BIO World Congress, the Chemical Watch U.S. Regulatory Summit, and the inaugural Product Stewardship Society conference. Ms. Roberts is also Vice President of B&C® Consortia Management, L.L.C. (BCCM).
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Lynn Bergeson has been working on industrial and agricultural chemical policy issues for over three decades, and has earned an international reputation for her deep and expansive understanding of TSCA, the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), the European Union (EU) Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) regulation, and especially how these regulatory programs pertain to nanotechnology, biotechnology, and other emerging transformative technologies.

Ms. Bergeson serves on the editorial board of Industrial Biotechnology Journal, is a member of the American College of Environmental Lawyers, has served as chair of the American Bar Association (ABA) Section of Environment, Energy and Resources, and speaks and writes frequently on legal, regulatory, and science policy issues unique to biobased products. Her articles have appeared in The Environmental Forum, Industrial Biotechnology, Natural Resources & Environment, and Environmental Quality Management, among other publications. Ms. Bergeson is Managing Partner of Bergeson & Campbell, P.C. (B&C®).
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Richard Engler, Ph.D., a 17-year veteran of EPA, is one of the most widely recognized experts in the field of green chemistry, having served as senior staff scientist in EPA's Office of Pollution Prevention and Toxics (OPPT) and leader of EPA's Green Chemistry Program. He has participated in thousands of TSCA substance reviews at EPA, as well as pre-notice and post-review meetings with submitters to resolve complex or difficult cases. Dr. Engler is Director of Chemistry with B&C.
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Jake Vandevort focuses on chemical product stewardship and the safe use of products for industry consortia. He helps develop and expand product stewardship and advocacy programs, develops and conducts communications outreach to government entities, and is a proven asset in facilitating membership retention and growth. He also manages conference calls, meetings, and other events, and monitors state and federal regulations with the goal of identifying opportunities and need for industry response.
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Charles Auer provides guidance on legal, policy, and scientific matters related to the regulation of chemicals under TSCA and related domestic and international chemical control laws.  He offers an exceptional level of policy and technical expertise in the testing, assessment, and management of new and existing chemicals under TSCA; approaches such as green chemistry, pollution prevention, Safer Choice, and other safer substitutes to meet corporate product stewardship goals; and commercialization of products from emerging chemical technologies, including synthetic biology and intergeneric microorganisms.  The former Director of the EPA OPPT, he brings over 35 years of experience to the consortium.
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B&C Consortia Management, L.L.C.

BRAG is managed by BCCM. BCCM creates and maintains the operational framework for BRAG and other consortia, allowing members to focus on critical issues most pertinent to their needs and essential to their success. BRAG provides services from strategic business and legal counsel to basic administrative support. Our staff is knowledgeable of the issues impacting the biobased chemical sector and helps drive the group toward success.

BCCM is affiliated with B&C, a Washington, D.C. law firm that helps companies that make and use chemicals commercialize their products, maintain compliance, and achieve competitive advantage as they market their products throughout the world.

BCCM is also affiliated with The Acta Group (Acta®), an international consulting firm that offers a broad range of regulatory and scientific consulting services to entities worldwide. Acta focuses on chemical and other heavily regulated product approval issues and the supply chain notification, customer demand, communication, media attention, and regulatory issues associated with these regulatory requirements. Acta has been a consistent player in all matters under the REACH regulation for over a decade, and is very much engaged in notifications and supply chain matters in China, Korea, Turkey, and elsewhere. 

Given its unique affiliation with B&C and Acta, BCCM can provide BRAG and its other consortia groups with immediate access to highly-trained, sophisticated attorneys, non-lawyer professionals, and scientists with significant expertise in competition law compliance, regulatory law, data management, data compensation, supply-chain management, and regulatory and legal/policy guidance. The expansive talent pools at BCCM, B&C, and Acta allow for all-inclusive, comprehensive services in management, regulatory, and scientific efforts for a wide range of global chemical management systems and the business and legal issues these systems invite.


 
BIOBASED AND RENEWABLE PRODUCTS ADVOCACY GROUP
2200 Pennsylvania Avenue, NW, Suite 100W
Washington, D.C. 20037
(202) 833-6580 | www.braginfo.org
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