On June 18, the US Environmental Protection Agency (EPA) quietly extended the deadline for submission of the inaugural Toxic Substances Control Act (TSCA) Chemical Data Reports, formerly known as TSCA Section 8(a) Inventory Update Reports. (Just in time, as the reports were due by June 30.) But don’t relax just yet – the revised due date is August 13, 2012, just a month away!
The CDR rule (40 CFR part 711) requires manufacturers and importers of certain chemical substances included on the TSCA Chemical Substance Inventory to report current data on the manufacturing, processing, and use of the chemical substances. (I know what you’re thinking: Didn’t we just report this information on our annual Toxic Release Inventory Form R submissions? But, really, this is something different.) The required data include current information on chemical substance production volumes, manufacturing sites, and how the chemical substances are used.
As amended in the August 16, 2011, Federal Register, the Inventory Update Rule was renamed the Chemical Data Reporting rule with the following reporting thresholds and requirements:
- The rule requires electronic reporting of the CDR data, using the EPA’s web-based reporting tool (e-CDRweb), accessible through the Central Data Exchange site (cdx.epa.gov).
- The reporting frequency will be once every four (4) years.
- For 2012, reporting is required if the production volume (domestically manufactured plus imported volumes) at a site met or exceeded 25,000 pounds during 2011. After 2012, reporting is required if the production volume of a chemical substance met or exceeded the 25,000-lb threshold in any calendar year since the last principal reporting year.
- For the 2012 submission period, the threshold for reporting processing and use information is 100,000 lbs. In subsequent submission periods, the reporting threshold will be 25,000 lbs.
- For certain chemical substances that are the subject of specific TSCA rules or orders, the reporting threshold is 2,500 lbs, effective for the 2016 and subsequent submission periods.
- Manufacturers (including importers) are required to report: company and parent company information; chemical identity; production volumes for previous years; quantities of chemicals used at the site; import and export information; whether a manufactured chemical is being recycled, remanufactured, reprocessed, or reused; processing and use information, including likely worker exposure to the chemical in specific industrial processes; commercial and consumer use with associated exposure information.
Reporting exemptions apply for water, polymers, microorganisms, “naturally-occurring substances” depending on their method of manufacture, and as “partial” exemptions, petroleum process streams and other chemicals listed in the rule.
For further information or assistance, visit the EPA TSCA website at www.epa.gov/iur/ (yeah, it still has the old Inventory Update moniker) or contact T. Cozzie Consulting.