Who We Are
Biobased and Renewable Products Advocacy Group (BRAG®)
Renewable chemicals are emerging at a fast pace, paving the way for new, innovative, and sustainable biobased products. A coalition of companies and trade associations committed to enhancing the legal and regulatory positioning of biobased products formed the Biobased and Renewable Products Advocacy Group (BRAG) to address issues specific to biobased chemical products and, in particular, the unique and somewhat complicated opportunities and challenges imposed on newer biobased chemicals under the federal Toxic Substances Control Act (TSCA) implemented by the U.S. Environmental Protection Agency (EPA). By bringing together biobased and renewable products innovators, TSCA legal experts, government affairs professionals, scientists, and science policy specialists, BRAG collectively provides an informed advocacy voice for policy change for biobased chemicals where opportunities exist to address challenges unique for this industry sector.
BRAG membership is open to biobased chemical manufacturers and companies/organizations that support them. BRAG is the only trade group solely focused on regulatory advocacy for biobased chemicals and products under TSCA. While we track issues such as the Renewable Fuel Standard (RFS) or larger generic chemical or biotechnology issues, our efforts do not overlap with other trade groups' existing efforts on those issues.
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.
Her 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).
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), and 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. She is 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).
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. He is Senior Policy Advisor with B&C.
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. Download vcard
Lauren Graham, Ph.D., guides and facilitates effective consortia performance in advocacy programs, public outreach, product stewardship, and testing and compliance. Dr. Graham offers BRAG members the scientific acumen she gained in academia and industry, and the organizational, editorial, and promotional skills honed in her work with the Royal Society of Chemistry. Download vcard
Charles Auer provides advice and analysis based on a seasoned understanding of regulatory, technical, policy, and strategic issues concerning testing, reporting/notification, assessment, management, and regulatory compliance requirements for new and existing chemicals, nanoscale materials, and intergeneric microorganisms. The former Director of the EPA OPPT, he brings over 35 years of experience to the consortium. Download vcard
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. More information on Acta is available at www.actagroup.com.
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.