Karyn Schmidt
Principal
Karyn Schmidt, a principal in the Public Policy Practice, has more than 30 years of experience working on chemicals management, environment, sustainability and other issues, as a lawyer and trade association policy representative. She advises companies and trade associations on the challenges that the chemicals sector faces, with her substantive legal background and relationships across industry, agencies and on Capitol Hill.
Karyn joined the firm after spending nearly 25 years at the American Chemistry Council (ACC), where she most recently served as senior director of regulatory and scientific affairs, and international team leader. Karyn has a deep fluency with the US Toxic Substances Control Act (TSCA), having worked on all aspects of implementation of the major 2016 amendments to TSCA. She was the TSCA risk management lead at ACC. She began her career as an environmental lawyer and worked as an in-house lawyer for ACC, before moving to the policy arena in 2015.
- Led industry efforts on implementation of the 2016 amendments to the federal TSCA, including promulgation of regulations and new policies, procedures and guidance, in areas ranging from prioritization of chemicals for risk evaluation; risk evaluation; manufacturer requested risk evaluations; risk management; TSCA Inventory reset and associated confidential business information issues; TSCA Chemical Data Reporting; fees rules and assessment; regulation of articles and import requirements; nomenclature and chemical equivalency; regulation of pyrolysis as chemical manufacturing; and new chemicals requirements and significant new use rules.
- Counseled on compliance with test orders under TSCA Section 4 and reporting requirements under TSCA Section 8.
- Counseled on compliance with TSCA polychlorinated biphenyls regulations, including transmission by natural gas pipeline and auto shredder residue.
- Led stakeholder discussions on a negotiated rulemaking on inorganic byproducts.
- Provided advocacy on state ingredient disclosure programs in California and New York; California’s Proposition 65; California’s Safer Consumer Products Program; and Washington’s Safer Products for Washington Program.
- Led the effort for the chemical industry to improve cost-benefit review in framework regulation for Clean Air Act regulations.
- Provided advocacy on extended producer responsibility, microplastics, chemical additives, recycled content, biobased content and associated life cycle sustainability issues, including standing up and expanding an industry microplastics research and advocacy program at both the domestic and global levels.
- Helped design legislative strategy to amend the Federal Food, Drug, and Cosmetic Act (FFDCA) with the Microbead Free Waters Act of 2015 to ensure that microbeads (a category of microplastics) are not classified by the Food and Drug Administration (FDA) as an adulterant.
- Stood up US and international research and advocacy programs on emerging microplastics issues and led state, federal and international advocacy on microplastics issues, including monomers (e.g., BPA, styrene and vinyl chloride) and plastics additives (e.g., phthalate esters and flame retardants).
- Compliance counseling on environmental marketing and environmental, social and governance (ESG) claims and advocacy with the US Federal Trade Commission to update the <em
.</em - Managed internal advertising claims audit and claims substantiation documentation for a client following scrutiny of public claims regarding state attorneys general.
- Helped lead regulatory strategy for the FDA to remove food contact authorization, and for the Environmental Protection Agency (EPA) to avoid listing of a chemical under TSCA Section 5(b)(4) as a chemical of concern.
- Managed a broad range of compliance issues and litigation arising under state and federal environmental laws, including TSCA, FFDCA, the Federal Hazardous Substances Act (FHSA), the Resource Conservation and Recovery Act (RCRA), the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), the Clean Air Act (CAA), the National Environmental Policy Act (NEPA), the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), the Emergency Planning and Community Right-to-Know Act (EPCRA), the Clean Water Act (CWA) and the Safe Drinking Water Act (SDWA).
- Managed a global network of chemical companies addressing chemicals management, trade, export and import and compliance issues in jurisdictions across the world.
Education
- William and Mary Law School, J.D., 1991
- James Madison University, B.S., 1988
Admissions
- Virginia, 1991
- Not admitted in the District of Columbia (pending); practice directly supervised by principals of the firm admitted in the District of Columbia
Courts
- U.S. Ct. of App., Fourth Circuit
- U.S. Dist. Ct., S. Dist. of West Virginia
- Speaker, “What’s Next for TSCA Risk Management,” Asphalt Roofing Manufacturers Association, March 19, 2025.
- Speaker, “What is Next for TSCA Litigation,” Enhesa (Chemical Watch), February 27, 2025.
- Speaker, “Recent Developments in TSCA Section 6, Risk Evaluations and Risk Management,” Regulatory Summit North America 2024, Enhesa (Chemical Watch), September 16, 2024.
- Moderator, “TSCA Reform – 8 Years Later – Risk Management,” Environmental Law Institute, June 25, 2024.
- Moderator, “TSCA Risk Management,” GlobalChem 2024, March 26, 2024.
- Moderator, “CEPA Implementation,” GlobalChem 2024, March 27, 2024.
- Speaker, “Global Impact From the EU Chemical Strategy for Sustainability: What’s Happening Worldwide as a Result?” The EU Chemicals Strategy for Sustainability: One Year On, Enhesa (Chemical Watch), October 20, 2021.
- Speaker, “A Two-Year Lookback on Trump’s Deregulatory Record,” Section on Administrative Law and Rulemaking, Regulatory Policy Committee, American Bar Association, July 12, 2019.
- Speaker, “TSCA Panel Session,” Enhesa (Chemical Watch), October 31, 2018.
- Speaker, “Federal Preemption: Legislative and Legal Challenges Facing Prop. 65,” Prop 65 Clearinghouse, September 24, 2018.
- Speaker, “State Product Labeling Regulations,” Southern Aerosol Technical Association, September 20, 2018.
- Speaker, “Reformed TSCA and Green Chemistry,” Safer Chemicals in Products Conference, Enhesa (Chemical Watch), September 18, 2018.
- Speaker,“PMN Submissions Under a Revised TSCA,” Enhesa (Chemical Watch), October 31, 2017.
- Speaker, “Panel Discussion: Dealing With the New TSCA,” Ohio Chemistry Technology Council, August 8, 2017.
- Speaker, “Industry Perspectives on Existing Chemical Risk Evaluations,” The Toxicology Forum, July 12, 2017.
- Speaker, “Consideration of Unreasonable Risk Under the Lautenberg Chemical Safety Act,” Society for Risk Analysis, January 10, 2017.
- Co-author, “Retailer Sustainability and the Supply Chain,” National Resources & the Environment, Spring 2012.
- Author, “Personal Jurisdiction in Internet Transactions,” West Virginia Defense Trial Counsel Notebook, Summer 1998.
- Author, “Rohm & Haas Was Right: Recovery of Government Oversight Costs in Private Party Response Actions,” 19 William & Mary Environmental and Policy Review 253, 1995.
- Speaker, “Superfund Update,” Environmental Law in Kentucky, April 1994.
- Speaker, “Hazardous Waste Management,” West Virginia Manufacturers Association Annual Environmental Seminar, Spring 1994.
- Co-author, “Changing a Promulgated Regulation,” Topical Workshop on the Technical Basis for Measuring, Modeling, and Mitigating Toxic Aerosols, 1993.
- Contributor, “Special Committee on Environmental Crimes, 1993 Annual Report, Natural Resources, Energy, and Environmental Law 1993: The Year in Review,” 1993.