Warren Lehrenbaum

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.

Firm/Organization: Crowell & Moring LLP

Blogs: C&M Health Law, Government Contracts Legal Forum, Retail & Consumer Products Law Observer

Latest Articles

Government Contracts Legal Forum

Join us for the Annual Toxic Substances Control Act

By Paul Freeman, Warren Lehrenbaum & Michael Boucher

May 18, 2018

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 of those chemicals—TSCA touches your business in ways few grasp, yet carries significant risk of costly business disruptions and enforcement…

C&M Health Law

New California Court of Appeal Decision May Impose Premium Taxes on California Health Plans

By David Didier Johnson & Warren Lehrenbaum

October 12, 2015

Since their inception, California health care service plans have been considered not to be insurers for purposes of the State’s 2.35 percent gross premium tax. Under a controversial ruling issued by the Court of Appeal, this could change. On September 25, the Court of Appeal held that a suit alleging that California’s Blue Shield and Blue Cross plans—which are otherwise regulated as health care service plans—are insurers for purposes of the State’s 2.35 percent gross…

Retail & Consumer Products Law Observer

Use Foam? You may be subject to a new proposed EPA rule

By Warren Lehrenbaum, Monica Welt & Chalana Williams

January 22, 2015

EPA has proposed a new rule to restrict the use of seven toluene diisocyanates (TDIs) in consumer products. TDIs are commonly used in the production of polyurethanes found in foams, coatings, elastomers, adhesives and sealants used in consumer products. Flexible foams (for cushioning) and rigid foams (for insulation) are the chief uses for TDI.Published on January 15, 2015, the proposed Significant New Use Rule (SNUR) would apply to all consumer products containing any of…

C&M Health Law

Pharmaceutical Take-Back Program Deadlines Are Here

By Warren Lehrenbaum & Monica Welt

November 12, 2014

With under a week remaining for drug producers to comply with the first stages of Washington State’s King County drug take-back and disposal program, industry and regulators alike are watching closely. As one of two first-in-the nation programs requiring drug manufacturers to bear the costs of organizing and implementing a drug take-back and disposal program for county residents, the program’s success may inspire wider adoption of laws requiring manufacturers to address end-of-life management for products.…

Retail & Consumer Products Law Observer

RCRA Challenges Faced by Retailers

By Cheryl A. Falvey, Dawn Miller & Warren Lehrenbaum

June 10, 2013

Retailers face serious challenges in complying with their obligations under Resource Conservation and Recovery Act (“RCRA”) and other federal environmental statutes in light of the wide variety of retail products covered by EPA’s waste disposal regulations. EPA recently expressed its intent to consider future rulemaking under RCRA governing retail products unsold, returned, or removed from shelves for inventory changes or recalls. According to the Unified Agenda, a Notice of Data Availability on the issue was…

Warren Lehrenbaum

Join us for the Annual Toxic Substances Control Act

New California Court of Appeal Decision May Impose Premium Taxes on California Health Plans

Use Foam? You may be subject to a new proposed EPA rule

Pharmaceutical Take-Back Program Deadlines Are Here

RCRA Challenges Faced by Retailers

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