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 & 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.
Affiliations
Admitted to practice: District of Columbia; Maryland
Other Affiliations
American Bar Association; Environmental Law Institute
Highlights, News & Knowledge
Speeches & Presentations
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"At the Forefront of Data Compensation," Pesticide Data Compensation and Protection in a Global Marketplace, Cary, North Carolina
(March 24, 2020).
Presenters: Warren Lehrenbaum and Amy Symonds.
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"Amended TSCA and Data Compensation," Pesticide Data Compensation and Protection in a Global Marketplace, Cary, North Carolina
(March 24, 2020).
Presenter: Warren Lehrenbaum.
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"Regulatory Developments at EPA," Retail Industry Leaders Association (RILA) Webinar
(March 10, 2020).
Speaker: Warren Lehrenbaum.
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"Amended TSCA and Data Compensation," Pesticide Data Compensation and Protection in a Global Marketplace, Cary, NC
(April 5, 2018).
Presenter: Warren Lehrenbaum.
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"Chemical Control Legislation in USA and Nanomaterials: State Focus, Including New California Safer Chemicals Requirements," ChemCon the Americas 2018: Seminar 4 - Chemical Control legislation in USA and Nanomaterials, New Orleans, LA
(February 6, 2018).
Panelist: Warren Lehrenbaum.
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"The New TSCA – An Overview," 2017 American Fuel & Petrochemical Manufacturers (AFPM) Environmental Conference, Denver, CO
(October 17, 2017).
Presenters: Warren Lehrenbaum and Amy Symonds.
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"TSCA Reform & What It Means For You," American Apparel & Footwear Association - What’s on Your Customers’ Shelf? The Latest on Compliance and Restricted Chemicals, Long Beach, CA
(January 24, 2017).
Presenter: Warren Lehrenbaum.
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"Breaking Developments in the Regulation of Textile Chemicals," Webinar
(June 28, 2016).
Presenters: Warren Lehrenbaum and Natalia R. Medley.
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"Got Chemicals? The State of Play on Chemical Security Regulations," Crowell & Moring Webinar
(December 17, 2014).
Presenters: Warren Lehrenbaum, Daniel W. Wolff, and Evan D. Wolff.
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"Changes in U.S. Chemical Laws: Impacts of TSCA Modernization," Crowell & Moring Webinar
(September 4, 2013).
Presenters: Cheryl A. Falvey, Warren Lehrenbaum, John Phillips, and Josh Tzuker.
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"Is California a Canary in the Coalmine? Emerging Trends and the Future of Chemical Regulation in California," Crowell & Moring Webinar
(January 24, 2012).
Co-Speakers: Warren Lehrenbaum, Kevin C. Mayer and Bridget E. Calhoun.
Publications
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"Environmental Law and Practice in the United States: Overview," Practical Law
(October 1, 2017).
Authors: David Y. Chung, Warren U. Lehrenbaum, Thomas A. Lorenzen, Kirsten L. Nathanson and Jennifer A. Giblin.
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"How TSCA Modernization May Harm Innovation, And What Companies Can Do In Response," Bloomberg BNA Daily Environment Report
(October 26, 2016).
Authors: Warren Lehrenbaum and Preetha Chakrabarti.
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"Regulatory Forecast 2016: What Corporate Counsel Need to Know for the Coming Year," a Crowell & Moring LLP publication
(January 2016).
Contributor.
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"Environment — Air, Water, Chemicals, Wildlife, and Vapor Are Key Issues," Crowell & Moring's Regulatory Forecast 2016
(January 2016).
Contributors: Thomas A. Lorenzen, Warren Lehrenbaum, and Jennifer A. Giblin. Also published in Westlaw Journal's Environmental Report.
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"Risk And Reward For Industry In EPA 'Safer Choice' Label," Law360
(April 28, 2015).
Authors: Cheryl A. Falvey, Warren Lehrenbaum, Monica M. Welt, and Daniel H. Leff.
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"Regulatory Forecast 2015: What Corporate Counsel Need to Know for the Coming Year," a Crowell & Moring LLP publication
(January 2015).
Contributor.
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"Use Foam? You may be subject to a new proposed EPA rule," Crowell & Moring's Retail & Consumer Products Law Observer
(January 22, 2015).
Co-Authors: Warren Lehrenbaum, Monica M. Welt, and Chalana Williams.
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"California Green-Lights Its Green Chemistry Regulations," DRI, Vol. 16, Issue 3
(November 6, 2013).
Co-Authors: Warren Lehrenbaum, Cheryl A. Falvey, Kevin C. Mayer, and Joshua Kaplowitz.
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"Pesticides, Chemical Regulation, and Right-To-Know 2012 Annual Report: Toxic Substances Control Act (TSCA)" ABA Environmental Law Annual Update
(Spring 2013).
Co-Authors: Monica M. Welt and Warren Lehrenbaum.
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"Frankenfood Fight: Why Mandatory Labeling of GMO Foods is Unnecessary and Unwise," Pesticide & Chemical Policy Week in Review
(October 26, 2012).
Co-Authors: John Fuson and Warren Lehrenbaum.
Client Alerts & Newsletters
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"EPA Issues Policy On Conditions For Enforcement Discretion During the Coronavirus Crisis,"
(March 27, 2020).
Contacts: Kirsten L. Nathanson, Robert Meyers, David Chung, Warren Lehrenbaum, Jennifer A. Giblin, Thomas A. Lorenzen, Peter Gray, Paul Freeman, Byron R. Brown, Leland P. Frost
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"OEHHA Clarifies Responsibilities and the Meaning of "Actual Knowledge" Under Prop 65 Regulations,"
Mass Tort, Product, and Consumer Litigation Alert
(January 29, 2020).
Contacts: Warren Lehrenbaum, Sigourney R. Haylock, Richard McNeil, Nina M. MacLeay
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"Warning: You May Owe EPA New Risk Evaluation Fees and Reporting Under TSCA,"
Environment & Natural Resources Law Alert
(January 28, 2020).
Contacts: Warren Lehrenbaum, Amy Symonds, Michael Boucher, Nina M. MacLeay, Leland P. Frost
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"March 1, 2019!,"
Environment & Natural Resources Law Alert
(February 7, 2019).
Contacts: Warren Lehrenbaum, John D. Conner, Jr., Amy Symonds, Michael Boucher
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"Processing Notices of Arrival During the 2018-2019 Government Shutdown,"
Environment & Natural Resources Law Alert
(January 10, 2019).
Contacts: Warren Lehrenbaum, John D. Conner, Jr., Amy Symonds, Michael Boucher
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"Final TSCA Inventory Reset Rule Now Effective; Clock is Ticking for Companies to Report,"
Environment & Natural Resources Law Alert
(August 22, 2017).
Contact: Warren Lehrenbaum
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"TSCA Inventory Reset Rule,"
Government Contracts Bullet Points
(June 29, 2017).
Contact: Warren Lehrenbaum
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"EPA Releases the Final TSCA Inventory Reset Rule ,"
Environment & Natural Resources Law Alert
(June 28, 2017).
Contact: Warren Lehrenbaum
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"UPDATE: EPA Intends to Postpone Effective Date of Nano Rule,"
Environment & Natural Resources Law Alert
(May 10, 2017).
Contacts: Warren Lehrenbaum, Peter Gray, John D. Conner, Jr.
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"EPA Issues New Reporting Rule for Nanoscale Materials ,"
Environment & Natural Resources Law Alert
(January 12, 2017).
Contact: Warren Lehrenbaum
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"EPA Announces the First Ten Chemicals for Risk Evaluation Under the "New TSCA","
Environment & Natural Resources Law Alert
(November 30, 2016).
Contact: Warren Lehrenbaum
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"CBP Proposes to Amend TSCA Certification Requirements,"
International Trade Bulletin
(September 13, 2016).
Contacts: Warren Lehrenbaum, Aaron Marx
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"This Month in International Trade - July 2016,"
International Trade Bulletin
(August 4, 2016).
Contacts: John B. Brew, Frances P. Hadfield, Edward Goetz, David (Dj) Wolff, Gordon McAllister, George D. Ruttinger, Edward Norman, Jeffrey L. Poston, Emmanuel Plasschaert, Jeane A. Thomas, CIPP/E, Evan D. Wolff, Frederik Van Remoortel, Carlton Greene, Jeffrey L. Snyder, Matthew B. Welling, Daniel Cannistra, Alexander H. Schaefer, Ian A. Laird, Eduardo Mathison, Warren Lehrenbaum
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"New Legislation Dramatically Alters Chemical Regulation in the U.S.,"
Environment & Natural Resources Law Alert
(July 22, 2016).
Contact: Warren Lehrenbaum
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"EU Proposing REACH Restrictions on Certain Substances In Textiles and Apparel,"
Advertising & Product Risk Management Alert
(July 13, 2016).
Contact: Warren Lehrenbaum
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"OSHA Publishes Long-Anticipated Revision to Silica Standards,"
Environment & Natural Resources: Occupational Safety & Health Alerts
(March 30, 2016).
Contacts: Daniel W. Wolff, Warren Lehrenbaum, Sherrie Armstrong Davis
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"EPA Unveils Significant Changes to Its Audit Policy Procedures,"
Environment & Natural Resources Law Alert
(June 19, 2015).
Contact: Warren Lehrenbaum
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"OSHA Issues HazCom Interim Guidance in Conjunction with Compliance Deadline,"
Environment & Natural Resources Law Alert
(June 5, 2015).
Contacts: Daniel W. Wolff, Warren Lehrenbaum
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"EPA Proposes New Regulations for Nanoscale Materials in Commerce,"
Environment & Natural Resources Law Alert
(March 27, 2015).
Contacts: Cheryl A. Falvey, Warren Lehrenbaum
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"EPA Unveils New "Safer Choice" Product Labels,"
Environment & Natural Resources Law Alert
(March 16, 2015).
Contacts: Warren Lehrenbaum, Cheryl A. Falvey
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"Insights From GlobalChem 2015,"
Environment & Natural Resources Law Alert
(March 9, 2015).
Contact: Warren Lehrenbaum
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"Got Chemicals? The State of Play on Chemical Security Regulations,"
Advertising & Product Risk Management Alert
(January 28, 2015).
Contacts: Daniel W. Wolff, Evan D. Wolff, Warren Lehrenbaum
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"Foam and Polyurethane Manufacturers and Importers Take Note: EPA Proposes SNUR for Seven TDIs,"
Environment & Natural Resources Law Alert
(January 20, 2015).
Contacts: Warren Lehrenbaum, Chalana Netasha Damron
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"Pharmaceutical Take-Back Program Deadlines Are Here,"
Advertising & Product Risk Management Alert
(November 12, 2014).
Contact: Warren Lehrenbaum
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"DHS Seeks Comments on Changes to Its CFATS Rule,"
Environment & Natural Resources Law Alert
(August 18, 2014).
Contacts: Evan D. Wolff, Maida Oringher Lerner, Daniel W. Wolff, Warren Lehrenbaum
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"EPA Signals Changes to Its Risk Management Plan Rule,"
Environment & Natural Resources Law Alert
(August 4, 2014).
Contacts: Daniel W. Wolff, Warren Lehrenbaum, Evan D. Wolff, Maida Oringher Lerner
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"Draft List of Priority Products Announced for California's Safer Consumer Products Program,"
Advertising & Product Risk Management Alert
(March 13, 2014).
Contacts: Cheryl A. Falvey, Warren Lehrenbaum
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"EO 13650 Working Group Urges Coordination With Local Emergency Responders,"
Environment & Natural Resources Law Alert
(March 7, 2014).
Contacts: Daniel W. Wolff, Warren Lehrenbaum, Evan D. Wolff
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"Stakeholder Input Sought on Options to Improve Chemical Facility Risk Management,"
Environment & Natural Resources Law Alert
(January 8, 2014).
Contacts: Daniel W. Wolff, Warren Lehrenbaum, Evan D. Wolff
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"Chemical Facility Safety Working Group Issues 90-Day Progress Report,"
Environment & Natural Resources Law Alert
(December 24, 2013).
Contacts: Daniel W. Wolff, Warren Lehrenbaum, Evan D. Wolff
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"OSHA Considering Significant Changes to Its Process Safety Management Standard,"
Environment & Natural Resources Law Alert
(December 11, 2013).
Contacts: Daniel W. Wolff, Warren Lehrenbaum
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"OSHA Introduces Voluntary Workplace Chemical Exposure Standards,"
Environment & Natural Resources Law Alert
(November 19, 2013).
Contacts: Warren Lehrenbaum, Clifford J. Zatz
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"House of Representatives Holds First Substantive Hearing on TSCA Reform Legislation,"
Environment & Natural Resources Law Alert
(November 14, 2013).
Contact: Warren Lehrenbaum
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"House Subcommittee Hearing on TSCA Highlights Weaknesses in Current Chemicals Law,"
Environment & Natural Resources Law Alert
(September 23, 2013).
Contacts: Warren Lehrenbaum, Cheryl A. Falvey
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"California Finalizes Green Chemistry Regulations,"
Advertising & Product Risk Management Alert
(September 19, 2013).
Contacts: Warren Lehrenbaum, Cheryl A. Falvey
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"EPA Announces New List of Chemicals Targeted for Risk Assessment Under TSCA, Including 20 Flame Retardants,"
Environment & Natural Resources Law Alert
(March 28, 2013).
Contact: Warren Lehrenbaum
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"State Government Coalition Issues Draft Guidance For Assessing Alternatives to "Chemicals Of Concern","
Advertising & Product Risk Management Alert
(March 26, 2013).
Contact: Warren Lehrenbaum
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"Proposed California Regulations Discourage Use of Flame Retardant Chemicals,"
Advertising & Product Risk Management Alert
(February 15, 2013).
Contacts: Cheryl A. Falvey, Warren Lehrenbaum
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"California Revises Green Chemistry Regulations--Again,"
Advertising & Product Risk Management Alert
(February 8, 2013).
Contact: Warren Lehrenbaum
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"EPA Reverses Course and Promises to Withdraw TSCA Section 8(d) Cadmium Rule,"
Advertising & Product Risk Management Alert
(December 14, 2012).
Contacts: Cheryl A. Falvey, Warren Lehrenbaum
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"New EPA Regulations on Cadmium Target Manufacturers and Importers of Consumer Products; Retail Distributors to be Targeted Next,"
Advertising & Product Risk Management Alert
(December 13, 2012).
Contacts: Cheryl A. Falvey, Warren Lehrenbaum
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"OSHA Changes to MSDS and Chemical Labeling: May 11 Public Meeting on the New GHS Standards,"
Advertising & Product Risk Management Alert
(May 4, 2012).
Contact: Warren Lehrenbaum
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"EPA to Expand Chemicals Testing for Endocrine Disruption,"
Advertising & Product Risk Management Alert
(November 16, 2010).
Contact: Warren Lehrenbaum
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"New Year Will Ring in California "Green Chemistry" Regulations,"
Advertising & Product Risk Management Alert
(October 27, 2010).
Contact: Warren Lehrenbaum
Media Mentions
Firm News & Announcements