Tuesday, February 14, 2012

What If I Missed My 2006 TSCA Inventory Update Report?

Between February 1 and June 30, chemical manufacturers and companies that import chemicals will be evaluating their production and/or import quantities and if needed will be submitting their inventory data to US EPA under the new Chemical Data Reporting (CDR)Rule.

Click here for an overview of the new Chemical Data Reporting (CDR)Rule.

Although new for 2012, the CDR is a revising to reporting rules that have existed for a number of years under the name "Inventory Update Reporting" or IUR. IUR reporting was required every 4-5 years, with the last reporting year being 2006.

As companies begin to assemble data for the 2012 CDR report, some discover that they may have been subject to earlier reporting and may have failed to submit the required reports.

Under the new CDR, companies who missed their reporting requirements in 2006 have an opportunity to use the new CDR tools to assemble a report for 2006 and submit it as a paper copy. However, in order to comply with the Agency's self-disclosure policy, once a violation has been discovered, a company has 21 days from the time of that discovery to disclose the violation in writing to EPA.

Caltha LLP provides specialized expertise to clients nationwide in the preparation and submital of TSCA reports, including new CDR reporting, preparing submitals under EPA self-disclosure policy, and preparing cost-effective chemical tracking and management programs.

For further information contact Caltha LLP at

info@calthacompany.com or Caltha LLP Website

No comments: