Case No. IA-2016-328900-1

Date issued: Feb. 04 2019

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TURBOFAC Commentary (372 words)

Notes:

1) The “REACH Consortium [] managed by a U.S. law firm” for which “accreditation (as a registered company) [allows] export [of] styrene to Europe” was the Styrene Reach Consortium, the management of which was transferred from McKenna Long & Aldridge LLP to Jones Day in 2014 (see https://jonesdayreach.com/wp-content/uploads/Relevant-information-for-purchasing-LoA-Styrene-Oct-2024-Copy.pdf, p. 1). More information about the Styrene Reach Consortium, can be found at that link. As is evident, the law firm administers a program where applicant fill out a “a letter of access” application form, and once a letter of access is granted, the applicant is granted access to certain data. Beyond the data, the Letter of Access appears to enable the holder to participate in a “joint submission” to the EU regulatory agencies that allow for the export of the materials at issue (see p. 10 of the linked PDF).
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