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Warren Lehrenbaum

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Warren Lehrenbaum represents individual companies and trade associations before the U.S. Environmental Protection Agency (EPA), the United States Department of Agriculture (USDA) and the Food and Drug Administration (FDA), where he advocates on behalf of individual products as well as broad policy issues.

Warren serves as a member on the firm's Environment and Natural Resources Group Steering Committee. His practice focuses on chemical regulation and biotechnology issues arising under the Toxic Substances Control Act (TSCA), the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), the Food Quality Protection Act (FQPA), the Federal Food, Drugs and Cosmetics Act (FFDCA), the Emergency Planning and Community Right-to-Know Act (EPCRA), and related State and Federal laws. He assists large and small companies in the chemical and biotechnology fields obtain regulatory approvals for their products, and he helps clients address ongoing compliance and product stewardship issues. Warren's counseling in these areas typically involves issues such as: assisting manufacturers of chemical or biotechnology products understand their registration, premarket notification, testing and reporting obligations, and assisting manufacturers of crop protection products in protecting their data compensation rights. He also assists companies in their day-to-day compliance with pollution control obligations under the Clean Water Act, the Resource Conservation and Recovery Act (RCRA) and other statutes.

A substantial portion of Warren's practice is devoted to helping clients develop and implement corporate compliance programs, including environmental auditing programs and comprehensive environmental management systems. He also assists clients in identifying instances of potential non-compliance and defending against administrative investigations and enforcement actions. Warren has negotiated successful settlements in numerous enforcement cases, often involving complex supplemental enforcement projects (SEPs) and challenging economic benefit and BEN model issues.

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A wave of recent changes in federal and state law pertaining to PFAS chemicals is likely to present both immediate and long-term challenges to the government contracting community. At the federal level, contractors that import products, parts, packaging, equipment or other articles with components that contain PFAS must confront new and extensive regulatory reporting requirements relating to such imports going back to 2011, and they must do so by May 2025. At the state level, a growing list of states are enacting total bans on the sale and distribution of such products and components. On top of this flurry of environmental regulatory activity, the Biden Administration continues to direct federal agencies to develop procurement strategies that prioritize the purchase of PFAS-free articles as part the Administration’s broader effort to leverage the federal procurement function in pursuit of climate and sustainability policy objectives.Continue Reading New Federal and State PFAS Requirements Pose Unique Challenges to the Government Contracting Community

Achieving and maintaining compliance with the Toxic Substances Control Act (TSCA) continues to pose day to day challenges for a wide range of government contractors, made all the more challenging by recent amendments to the TSCA regime.  By governing the import, manufacture, and processing of chemical substances—together with the subsequent export, distribution, use, and disposal…