Monday, October 11, 2010

TSCA Section 8(a) Compliance - TSCA Reporting

[Note: Section 8(a) rule was revise din August 2011. Click here to review summary of new Chemical Data Reporting (CDR) rule]

On January 1, 2010, 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.

Under Section 8(a) of the Toxic Substances Control Act (TSCA), 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 TSCA. The IUR requirements are the most broadly applicable of all the TSCA requirements.

The IUR was first required in 1986. In 2003 and again in 2005, EPA amended the IUR, expanding the range of chemicals and plant sites reporting, expanding the type of data reported, raising the production volume threshold that triggers reporting, and making certain further adjustments. Under the new IUR requirements, every five years manufacturers and importers producing 25,000 pounds or more of a reportable chemical substance must report the identity of the chemical substance and basic manufacturing information. Additionally, manufacturers and importers producing 300,000 pounds or more must also report basic domestic processing and use information. In 2010, EPA has proposed additional amendments to the reporting requirements

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

Caltha LLP Website

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