Wednesday, April 6, 2011

Electronic Submittals For New Chemical Notices Required Under TSCA

Beginning today, companies can no longer submit their new chemical notices and support documents on paper for EPA’s review. U.S. Environmental Protection Agency will require electronic submissions for new chemical notices under the Toxic Substances Control Act (TSCA).

On April 6, 2010, EPA issued a final rule that put in place a 2-year phase out of paper and optical disc reporting for new chemical notices to the agency. The rule included a 1-year phase out of paper reporting and a 2-year phase out of optical disc reporting.

Under TSCA, companies are required to submit new chemical notices, including pre-manufacture notices (PMNs), to EPA at least 90 days prior to the manufacture or import of the chemical. EPA reviews the notice and can set conditions to be placed on the use of a new chemical before it enters into commerce. EPA receives around 1,000 new chemical notices each year, including hundreds of pages of supporting material. Companies are required to submit these notices using EPA's electronic PMN software either on optical disk (for one more year) or via EPA’s Central Data Exchange (CDX).

Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EH&S compliance procedures, and preparing cost-effective EH&S management programs.

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