Sara Beth Watson

Sara Beth Watson leads Steptoe’s Toxic Substances Control Act (TSCA) team and handles a wide range of environmental, chemical regulatory and occupational health and safety litigation and compliance counseling, including the integration of various regulatory requirements into a comprehensive compliance strategy for the regulated entity.

In the area of industrial chemicals, alcohols, and pesticides, she counsels clients on compliance strategies, including market approvals, defends enforcement actions, including negotiations with regulators, and provides advocacy advice. She also provides compliance assistance and defends enforcement actions on hazardous waste, contaminated property, water, and air issues.

Sara Beth provides compliance assistance to companies regarding the US Food and Drug Administration (FDA) regulation of drugs, medical devices, direct and indirect food additives, and dietary supplements, as well as FDA and US Department of Agriculture labeling and import/export regulations.

Sara Beth develops OSHA compliance strategies and citations response strategies including negotiations with Area Administrators, Regional Department of Labor solicitors, and Department of Labor headquarters officials. She also defends companies in administrative hearings.

In the transaction area, Sara Beth provides advice on drug, devices, food and environmental issues and identifies potential risks for a wide range of clients on transactions including asset purchases, mergers, real property acquisition and other acquisitions. She also works on NEPA and historic property (cultural resources) issues related to project development.

Sara Beth served as a resource member to the EPA’s negotiated rulemaking on All Appropriate Inquiry on behalf of the ABA Section of Environment, Energy and Resources (SEER) and was an advisor to the Uniform Environmental Covenants Act drafting committee. She writes and lectures extensively in the areas of device, drug and chemical regulation, transactions, and worker safety issues.

She provides compliance counseling to companies and trade associations regarding TSCA, the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), the Resource Conservation and Recovery Act (RCRA), the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), the Emergency Planning and Community Right to Know Act (EPCRTKA), the Clean Air Act (CAA), the Clean Water Act (CWA), the National Environmental Policy Act (NEPA), the Occupational Safety and Health Act (OSHA), the Federal Food Drug and Cosmetic Act (FFDCA), the Chemical Facility Anti–Terrorism Standards (CFATS), the Controlled Substances Act and related federal and state regulatory programs such as California’s Safe Drinking Water and Toxic Enforcement Act (Proposition 65).