Lawrence Culleen represents clients on administrative, regulatory, and enforcement matters involving federal agencies such as the US Environmental Protection Agency (EPA), the US Department of Agriculture, the US Food and Drug Administration, and the Consumer Product Safety Commission. Mr. Culleen has broad experience advising clients on US and international regulatory programs that govern commercial and consumer use chemicals, pesticides and antimicrobials, as well as the products of biotechnology and nanoscale materials.

Prior to joining the firm, Mr. Culleen held significant positions at EPA serving as a manager in various risk-management programs which oversee pesticides, chemical substances, and biotechnology products.

During his tenure in the federal government, Mr. Culleen served as its representative on core EPA programs to a variety of interest groups, trade associations, and government bodies, both foreign and domestic, including international cooperative organizations.

Focus Areas

  • Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)
  • Toxic Substances Control Act (TSCA)
  • "Right-to-Know" legislation (e.g., Proposition 65, EPCRA 313)
  • International Environmental/Chemical/Consumer Product Standards (e.g., REACH, GHS)
  • Consumer Product Safety Act

Experience

  • Provides day-to-day counsel to leading manufacturers in the US and abroad of chemical substances and formulations used in antimicrobials, personal and household care products on labeling, testing, licensing, and adverse effects reporting pursuant to TSCA , FIFRA, CPSA, and Directives in the EU.
  • Advises clients concerning current and potential future standards concerning the development of new chemical substances, novel devices, and genetically modified and nano-scale materials that are subject to various federal and state laws.
  • Negotiates TSCA and FIFRA settlements and compliance audit agreements with EPA for chemical and consumer products companies, and provides representation during general inquiries, investigations, and enforcement proceedings.
  • Provides counsel in preparing comments during chemical regulatory development processes and information and data collection efforts.
  • Assists multinational clients in establishing global systems to identify, understand, and comply with international and US requirements concerning pesticides, and maximum residue levels for crops harvested and sold for consumer use worldwide.
  • Represents a variety of specialty chemical manufacturers in negotiations with EPA concerning new chemical reviews and consent orders addressing the production and use of new chemicals, including innovative new technologies employed in high-tech sectors as well as the products of biotechnology and nano-scale particles.

Perspectives

Will EPA Be Designating Entire Categories of PFAS as CERCLA Hazardous Substances?
Environmental Edge: Climate Change & Regulatory Insights
The Chemical Compound—February 2023
Legal Updates on High Priority Chemicals and Important Chemical-Regulatory Developments
Five Key Features of the EU’s Proposed PFAS Restrictions
Environmental Edge: Climate Change & Regulatory Insights
Maine Issues Proposed Rule Concerning PFAS-Containing Products
Environmental Edge: Climate Change & Regulatory Insights
Two New Hazardous Substances: The Impact of Listing PFOA and PFOS Under the Comprehensive Environmental Response, Compensation, and Liability Act (pdf)
The Journal of Federal Agency Action, Volume 1, Number 1
More

Recognition

Chambers USA
Environment (DC) (2022-2023)
The Legal 500 US
Environment: Regulatory (2017-2019, 2022)
ABA Best Papers
Received "Best Paper" honor for "The Chemical-Regulatory Reform Freight Train-All Aboard!" prepared for the ABA's Section of Environment, Energy, and Resources 39th Annual Conference on Environmental Law (2010)

Credentials

Education
  • J.D., The George Washington University Law School, 1982
  • B.A., George Washington University, 1979
Admissions
  • District of Columbia
  • Maryland
Government & Military Service
  • Chief of Staff to the Assistant Administrator, US EPA
  • Acting Director, Registration Division in the Office of Pesticide Programs, US EPA
  • Chief, New Chemicals Branch, US EPA
  • Director, Asbestos-In-Schools Loan and Grant Program, US EPA
Activities
  • Vice-Chairperson, American Bar Association Committee on Pesticides, Chemical Regulation, and Right-to-Know; former Vice-Chairperson
  • Former Adjunct Professor of Environmental Law, The George Washington University National Law Center
  • Member, Local Governmental Public Commission
  • Former Board of Directors and Executive Committee Member several community-based non-profit organizations
Overview

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