On January 1, a new TSCA Inventory Update Rule (IUR) reporting year began. Although reports will not be submitted until 2011, manufacturers and importers need to be collecting the necessary data to be able to submit their IUR report for 2010.
Every five years, companies that either manufacture or import chemicals or mixtures of chemicals on the “TSCA List” must report their activities. The reporting requirement, referred to as the “Inventory Update Rule”, or IUR, is only one of several requirements in the Toxic Substances Control Act (TSCA) enacted in 1985. The IUR requirements are the most broadly applicable of all the TSCA requirements.
Historically, compliance with TSCA and the IUR requirements has been a continuing challenge for facilities. It is somewhat speculation to project why on-going TSCA compliance tends to be more difficult; however, there are some factors which may be an influence:
- IUR reporting is required infrequently.
- There is no State equivalent to TSCA.
- Importers of chemicals are equivalent to manufacturers of chemicals.
- Effect of centralized/decentralized purchasing.
For more information on the IUR, including a flow chart to determine if the Rule applies to your operations, go to:
TSCA Inventory Update Rule Regulatory Briefing
Caltha LLP provides specialized expertise to clients nationwide in the development of straighforward TSCA IUR tracking procedures and preparing TSCA IUR reports.
For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website
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