Amended Reporting Requirements under TSCA Approaching Fast!

As you may be aware, 2012 is a Toxic Substances Control Act (TSCA) chemical reporting year.  This means if you manufacture (import), process, distribute, and/or use chemical substances for commercial purposes, you may be subject to TSCA reporting.  Even your chemical manufacturing byproducts may be subject to reporting requirements.

What makes this reporting cycle more noteworthy is that in August 2011, the Environmental Protection Agency (EPA) issued amendments to the TSCA Inventory Update Reporting (IUR) rule. The IUR is now the Chemical Data Reporting (CDR) rule.  Among other changes, this new rule revises how to determine if a chemical meets a reporting threshold and institutes gradual reductions in reporting thresholds over the next two reporting cycles.  A link to the new rule is provided below.

In addition to the reduced reporting threshold for certain chemicals, there have been other changes including a modification in the reporting frequency from every five years to every four years.

CDR submissions must be completed electronically through the EPA’s e-CDRweb reporting tool and Data Exchange (CDX) system between February 1, 2012 and June 30, 2012.  CDX accounts can take a couple of weeks to set up, and the reporting process can be very time consuming, so it would be wise to start early.

If you have any questions regarding the TSCA reporting requirements or require assistance with an environmental permit or plan, contact Matthew Schroeder (mschroeder@dragun.com) at 248-932-0228.

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OPPT-2009-0187-0393

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