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Letters on TSCA and FFDCA Jurisdictional Issues

The letters below relate to jurisdictional issues between the Toxic Substances Control Act (TSCA) and the Federal Food, Drug, and Cosmetic Act (FFDCA).

The first letter was dated June 10, 1994 and outlines EPA's position on TSCA jurisdictional issues regarding process wastes and effluents from pharmaceutical manufacturing.

The second letter was dated March 30, 1994 and outlines EPA's position on TSCA and FFDCA jurisdictional issues.

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June 10 , 1994 letter to Latham & Watkins re: "FDA Exemption" under TSCA (PDF)(10 pp, 4 MB)
March 30, 1994 letter to Sidley & Austin re: "TSCA/FFDCA Jurisdiction" (PDF)(11 pp, 658 K)