Rule On Reporting Mercury And Mercury Added Products

The Lautenberg Act TSCA amendments established reporting deadline(s) and information requirements periodic update and publication of the inventory of mercury supply, use, and trade in the United States. As required under TSCA, the reporting requirements would apply to any person who manufactures mercury or mercury-added products, or otherwise intentionally uses mercury in a manufacturing process.


Mislabeled Mercury Waste Drum
Identified During RCRA Audit


On October 26, 2017, EPA issued a proposed rule to implement TSCA section 8(b)(10)(D), which requires EPA to issue a final rule no later than 2 years after the enactment of the Lautenberg Act TSCA amendments that establishes reporting deadline(s) and information requirements. As required under TSCA, the reporting requirements would apply to any person who manufactures mercury or mercury-added products, or otherwise intentionally uses mercury in a manufacturing process.EPA published the first inventory in March 2017. Based on the information collected, TSCA further directs EPA to identify any manufacturing processes or products that intentionally add mercury and recommend actions to achieve further reductions in mercury use.

EPA proposed reporting requirements in the Federal Register of October 26, 2017  to assist in the preparation of an “inventory of mercury supply, use, and trade in the United States.” Subsequently the deadline for the comment period was extended  to January 11, 2018. The final rule is anticipated to be published by July 1, 2018.

 

Caltha LLP | Your EH&S Compliance, 

Auditing and EMS/SMS Partner

TSCA Compliance Expert Technical Support For NJ Chemical Company

Caltha LLP Project Summary

Project: TSCA Certification Support
Client: Chemical Distributor 
Location(s): New Jersey


Key Elements: TCSA Import Certification, TSCA reporting, Hazardous Material Storage, Hazardous Material Transportation


Overview: Caltha LLP has provided on-going ad hoc technical support to this chemical importer and distribution company. Services are provided on an "as needed" basis and include review of product SDS, chemical storage requirements, and TSCA import certifications (positive certification, negative certification).


Click here for more information on Caltha LLP TSCA Compliance services.

Proposed Amendment of TSCA Chemical Data Reporting Rule

EPA intends to establish a Negotiated Rulemaking Committee under the Federal Advisory Committee Act (FACA) and the Negotiated Rulemaking Act (NRA) to negotiate a proposed rule would limit chemical data reporting requirements for manufacturers of certain inorganic byproduct chemical substances.. The objective of the Negotiated Rulemaking Committee will be to negotiate a proposed rule that would limit chemical data reporting requirements under section 8(a) of the Toxic Substances Control Act (TSCA), as amended by the Frank. R. Lautenberg Chemical Safety for the 21st Century Act, for manufacturers of any inorganic byproduct chemical substances, if byproduct chemical substances are subsequently recycled, reused, or reprocessed.

What is the Negotiated Rulemaking Process?

In 1986, EPA created the Inventory Update Reporting (IUR) regulation under TSCA section 8 to collect, every four years, limited information on the manufacture (which includes import) of organic chemical substances listed on the TSCA Inventory, thereby providing more up-to-date production volume information on the chemical substances in U.S. commerce. In 2005, EPA amended the IUR to require the reporting of information on inorganic chemical substances and to collect additional manufacturing, processing, and use information. Manufacturers of inorganic chemical substances first reported under the IUR in 2006. They also reported under the CDR in 2012 and 2016. Specific reporting requirements for these manufacturers were phased in, to allow for the industry to better understand the reporting requirements and for EPA to gain a better understanding of the industry. In recent years, the regulatory requirement to report byproduct chemical substances (and the availability of exemptions from that requirement) has been a frequent topic of discussion.

In 2011, EPA also stated that it would examine CDR information related to byproduct chemical substances to identify whether there are segments of byproduct chemical substance manufacturing for which EPA can determine that there is no need for the CDR information to continue to be collected, either for 2016 or for future reporting cycles. On June 22, 2016, TSCA was amended by the Lautenberg Act. TSCA now includes a requirement that EPA enter into a negotiated rulemaking, pursuant to the NRA, to develop and publish a proposed rule to limit the reporting requirements under TSCA section 8(a), for manufacturers of any inorganic byproduct chemical substances, when such byproduct chemical substances, whether by the byproduct chemical substance manufacturer or by any other person, are subsequently recycled, reused, or reprocessed.

Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs.
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Caltha LLP at info@calthacompany.com or Caltha LLP Website

Chemical Data Reporting For Chemical Importers Under TSCA Due By September 30, 2016

Reporting under the TSCA Chemical Data Reporting (CDR) rule is due by September 30, 2016. Chemical importers are regulated like chemical manufacturers under the TSCA Chemical Data Reporting Rule. Every four years, importers of chemicals are required to submit Form U disclosing chemical import quantities for chemical substances. The current reporting period is July 1 through September 30, 2016, covering calendar years 2012-2015.


Caltha LLP provides specialized expertise to importers to keep them in compliance with the various regulations that apply. Click here for more information on State and EPA regulations that apply to importers of chemical substances

RCRA and TSCA Compliance Audit For Multiple Facilities To Meet ISO 14001 Requirements

Caltha LLP Project Summary

Project: Combined RCRA and TSCA PCB Management Audit For 26 Facilities
Client: Electric Utility
Location(s): 26 locations

Key Elements: RCRA hazardous waste audit, TSCA PCB management, Used oil management, Universal waste management, ISO 14001

Overview: Caltha was retained to conduct a compliance audit of 26 facilities to assess compliance with:

• EPA hazardous waste rules (40 CFR Part 260-262)
• Minnesota hazardous waste rules (MPCA Chapter 7045)
• North Dakota hazardous waste rules
• Federal and State requirements for used oil management (40 CFR Part 279)
• Federal and State requirements for universal waste management (40 CFR Part 273)
• EPA Toxic Substances Control Act (TSCA) requirements for PBC management (40 CFR Part 261)

Audits were conducted to satisfy ISO 14001 standards for scheduled audits, under ISO 14001 clause 4.5.2.1. Audits were completed with a combination of records review and on-site inspections.



For more information on Caltha LLP auditing services, go to the Caltha Compliance and EMS SMS Audit Page



Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website 

 

Lead Renovation, Repair, and Painting Program Application To Public and Commercial Buildings

US EPA has announced that it will conduct a public meeting on June 26, 2013 to gather public comment regarding extending its Lead Renovation, Repair, and Painting Program to public and commercial buildings. In 2010, EPA issued an advance notice of proposed rulemaking (ANPRM) concerning renovation, repair, and painting activities in public and commercial buildings.

EPA is in the process of determining whether these activities create lead-based paint hazards, and, for those that do, developing certification, training, and work practice requirements as directed by the Toxic Substances Control Act (TSCA). EPA has also reopened the comment period for the December 31, 2012 Federal Register document to allow for additional data and other information to be submitted by the public and interested stakeholders. EPA specifically requested information on the following:

1. The manufacture, sale, and uses of lead-based paint after 1978.
2. The use of lead-based paint on public and commercial buildings.
3. The frequency and extent of renovations of public and commercial buildings.
4. Work practices used to renovate public and commercial buildings.
5. Dust generation and transportation from exterior and interior renovations of public and commercial buildings.

Click here for further background on the application of the LBP Rule to public and commercial buildings




Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs.
For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

Proposed SNUR For Carbon Nanomaterials

EPA is proposing significant new use rules (SNURs) under the Toxic Substances Control Act (TSCA) for 37 chemical substances which were the subject of premanufacture notices (PMNs). Seventeen of these chemical substances are also subject to TSCA section 5(e) consent orders issued by EPA. This action would require persons who intend to manufacture, import, or process any of these 37 chemical substances for an activity that is designated as a significant new use by the proposed rule to notify EPA at least 90 days before commencing that activity. Comments must be received on or before April 26, 2013.

The proposed rule includes 14 PMN substances whose reported chemical names include the term "carbon nanotube" or "carbon nanofibers." Because of a lack of established nomenclature for carbon nanotubes, the TSCA Inventory names for carbon nanotubes are currently in generic form, e.g., carbon nanotube (CNT), multi-walled carbon nanotube (MWCNT), double-walled carbon nanotube (DWCNT), or single-walled carbon nanotube (SWCNT). EPA uses the specific structural characteristics provided by the PMN submitter to more specifically characterize the TSCA Inventory listing for an individual CNT. EPA is using the specific structural characteristics for all CNTs submitted as new chemical substances under TSCA to help develop standard nomenclature for placing these chemical substances on the TSCA Inventory.

Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs.
For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

Revised TSCA Requirements for Ethaneperoxoic acid, 1,1-dimethylpropyl ester

Under the Toxic Substances Control Act (TSCA), EPA is proposing to amend the significant new use rule (SNUR) for the chemical ethaneperoxoic acid, 1,1-dimethylpropyl ester, which was the subject of premanufacture notice (PMN). This action would amend the SNUR to allow certain uses without requiring a significant new use notice (SNUN), and would extend SNUN requirements to certain additional uses. EPA is proposing this amendment based on review of new toxicity test data. Comments must be received on or before February 27, 2013.

After the review of new test data subsequent to issuance of the TSCA section 5(e) consent order for the chemical and consideration of the factors included in TSCA section 5(a)(2), EPA determined that the chemical substance meets one or more of the concern criteria, but that these criteria are no longer met for the personal protective equipment, hazard communication, and specific use notification requirements. Consequently, EPA is proposing this modification to the SNUR.


Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs.
For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

Proposed SNURs Under Toxic Substances Control Act

EPA is proposing significant new use rules (SNURs) under the Toxic Substances Control Act (TSCA) for four chemical substances which were the subject of premanufacture notices (PMNs). The proposed rule would require persons who intend to manufacture, import, or process any of the chemical substances for an activity that is designated as a significant new use by this proposed rule to notify EPA at least 90 days before commencing that activity. Comments on the proposed rule must be received on or before February 22, 2013.

The chemicals subject to the proposed SNUR are:

• Pentane, 1,1,1,2,3,3- hexafluoro-4-(1,1,2,3,3,3- hexafluoropropoxy)-CAS number: 870778-34-0
• Three partially fluorinated alcohol substituted glycols (generic).

As background, Section 5(a)(2) of TSCA authorizes EPA to determine that a use of a chemical substance is a "significant new use." EPA must make this determination by rule after considering all relevant factors, including

1. The projected volume of manufacturing and processing of a chemical substance.
2. The extent to which a use changes the type or form of exposure of human beings or the environment to a chemical substance.
3. The extent to which a use increases the magnitude and duration of exposure of human beings or the environment to a chemical substance.
4. The reasonably anticipated manner and methods of manufacturing, processing, distribution in commerce, and disposal of a chemical substance.

Once EPA determines that a use of a chemical substance is a significant new use, TSCA section 5(a)(1)(B) requires persons to submit a significant new use notice (SNUN) to EPA at least 90 days before they manufacture, import, or process the chemical substance for that use.


Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website 

 

Expansion of Lead Renovation, Repair, and Painting (RRP) Rule

In 2010, EPA issued an advance notice of proposed rulemaking concerning renovation, repair, and painting activities on and in public and commercial buildings. EPA is in the process of determining whether these activities create lead-based paint hazards. For those that do, EPA will develop certification, training, and work practice requirements as directed by the Toxic Substances Control Act (TSCA). EPA has now opened a comment period to allow for additional data and other information to be submitted by the public and interested stakeholders. Comments must be received on or before April 1, 2013. EPA plans to hold a public meeting on June 26, 2013.

As background, Title IV of TSCA was enacted to reduce lead exposures, particularly those resulting from lead-based paint. TSCA requires EPA to revise its Lead-based Paint Activities Regulations to apply to those renovation and remodeling activities in target housing, public buildings constructed before 1978, or commercial buildings that create lead-based paint hazards. In April 2008, EPA issued the final Lead Renovation, Repair, and Painting (RRP) Rule. The RRP Rule covers renovation, repair, and painting activities in target housing, which is most pre-1978 housing, and child-occupied facilities, defined in the rule as a subset of public and commercial buildings in which young children spend a significant amount of time.

Shortly after the RRP Rule was published, several lawsuits were filed challenging the rule, asserting that EPA failed to address renovation activities in public and commercial buildings. As part of a settlement agreement, EPA agreed to commence rulemaking to address renovations in public and commercial buildings, other than child-occupied facilities. EPA has agreed to either sign a proposed rule covering renovation, repair, and painting activities in public and commercial buildings, or determine that these activities do not create lead-based paint hazards by July 1, 2015.

In addition, EPA agreed to hold a public meeting on or before July 31, 2013, and offer an opportunity for stakeholders and other interested members of the public to provide data and other information that EPA may use in making its regulatory determinations. Of particular interest to EPA for developing a proposed rule is information concerning:

1. The manufacture, sale, and uses of lead-based paint after 1978.

2. The use of lead-based paint in and on public and commercial buildings.

3. The frequency and extent of renovations on public and commercial buildings.

4. Work practices used in renovation of public and commercial buildings.

5. Dust generation and transportation from exterior and interior renovations of public and commercial buildings.


Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs.
For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website 

 

TSCA Rule On Cadmium and Cadmium Compounds Withdrawn

EPA is withdrawing the final Toxic Substances Control Act (TSCA) section 8(d) Health and Safety Data Reporting Rule that it issued on December 3, 2012. The health and safety data reporting rule would have required manufacturers (including importers) of cadmium or cadmium compounds, including as part of an article, that have been, or are reasonably likely to be, incorporated into consumer products to report certain unpublished health and safety studies to EPA. Since the final rule's issuance, EPA has received a number of letters, including requests for withdrawal, asking questions and raising concerns about the scope and extent of the immediate final rule that indicate that there is significant confusion and uncertainty about the final rule in certain industrial sectors subject to the final rule. EPA believes that some of the points raised in the letters warrant additional consideration by the Agency.


Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs.
For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

Rules For NP and NPE Under TSCA and EPCRA 313

EPA has initiated rulemaking to restrict the use of nonylphenol (NP) and its ethoxylates (NPEs) under a proposed significant new use rule (SNUR) using existing Toxic Substances Control Act (TSCA) authority and under the Emergency Preparedness and Community Right-to-Know Act (EPCRA). EPA plans to issue the proposal in the next year. NP and NPEs are used in industrial laundry detergents, oil spill dispersants, personal care products, industrial soaps, and other products, but the agency has raised concerns that the chemicals are highly toxic to aquatic life, environmentally persistent, moderately bioaccumulative and potential endocrine disruptors.

As part of the action plan, EPA is working with the industrial laundry industry to phase out that use of the chemicals by the end of 2014. The action plan also says the agency intends to encourage manufacturers of all NPE-containing direct-release products, such as firefighting gels and foams, dust-control agents and de-icers, to move to NPE-free formulations. Earlier this year the agency released an alternatives assessment for NP and NPEs through its Design for the Environment program that identified eight safer alternatives. The TSCA section 5 SNUR would serve as the next step under EPA's action plan, complementing the phaseout by restricting industry from reintroducing the chemical in new applications.

The SNUR would require persons who intend to manufacture, import, or process certain NP and NPE chemicals for an activity that is designated as a significant new use by the proposed rule to notify EPA at least 90 days before commencing that activity. The notification would provide EPA with the opportunity to evaluate the intended use and, if necessary, to prohibit or limit that activity before it occurs to prevent unreasonable risk to human health or the environment.

The action plan also indicates EPA may add the chemicals to its EPCRA Section 313 Toxics Release Inventory (TRI) list, and has proposed under TSCA section 5(b)(4) to put NPs and NPEs on a list of chemicals that present or may present an unreasonable risk of injury to health or the environment. The chemicals-of-concern list alone would have no regulatory consequences or trigger a rule.

Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs.
For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

PCB Waste From Building Demolition - Reinterpretation of PCB Bulk and PCB Remediation Wastes

The EPA Office of Resource Conservation and Recovery has announced its intention to reinterpret its guidance regarding PCB-contaminated building materials.

In February 2012, the EPA solicited comment on a draft reinterpretation of its position regarding the status of PCB-contaminated building materials under the definition of PCB bulk product waste. EPA received several questions from the regulated community regarding the disposal and cleanup requirements for PCB-contaminated building materials. The Toxic Substances Control Act (TSCA) regulations at 40 CFR 761 provide disposal and cleanup requirements for PCBs. The disposal and cleanup requirements for PCB-contaminated building material depend on whether the material is classified as a PCB bulk product waste or PCB remediation waste. Waste derived from caulk or paint containing PCBs at > 50 parts per million (ppm) is defined as PCB hulk product waste in 40 CFR 761.3. The definition of PCB bulk product waste includes -non-liquid bulk wastes or debris from the demolition of buildings and other man-made structures manufactured, coated, or serviced with PCBs." Other PCB bulk product wastes may include, but are not limited to, mastics, sealants, or adhesives containing PCBs at > 50 ppm. PCB remediation waste is defined as "waste containing PCBs as a result of a spill, release, or other unauthorized disposal...". and leaching may he considered a release of PCBs.

Current EPA guidance states that building material contaminated by the migration of PCBs from PCB bulk product waste, such as caulk or paint, is considered a PCB remediation waste. The proposed reinterpretation would have modified this guidance to specify that only PCB contaminated building material from which the PCB bulk product has been removed is a PCB remediation waste. Under the proposed reinterpretation, the distinction was made whether or not the PCB bulk product is still attached to the building materials.

The reinterpretation finalized in October 2012 allows building material (i.e., substrate) "coated or serviced" with PCB bulk product waste (e.g., caulk, paint, mastics, sealants) at the time of designation for disposal to be managed as a PCB bulk product waste, even if the PCBs have migrated from the overlying bulk product waste into the substrate, provided there is no other source of PCB contamination on or in the substrate. However, if the substrate is not "coated or serviced" (i.e.. the PCB bulk product waste, such as caulk or paint has been removed from the building material) at the time of designation for disposal, and the substrate is contaminated with PCBs that have migrated from the bulk product waste (or from another unauthorized disposal), the substrate would be considered a PCB remediation waste.

The current reinterpretation addresses the possibility that during a cleanup or demolition process, PCB bulk product waste (e.g.. caulk, paint. mastics, and sealants) could separate from the contaminated building material before all of the waste is physically placed in the final disposal facility. At the time of designation for disposal, the contaminated building material would be deemed a PCB bulk product waste if the PCB material (e.g.. caulk, paint, mastic or sealant) is still attached. This label as PCB bulk product waste would stay with the contaminated building materials. EPA recommends developing an abatement plan to document the decision to designate building materials as bulk product waste at the time of designation for disposal. If the PCB material has already been removed or flaked off at the time of designation for disposal, the building material would be deemed a PCB remediation waste, as established under the existing interpretations.


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

For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website 

 

Significant New Use Rules Issued For 107 Chemicals

On September 21, EPA published significant new use rules (SNURs) under the Toxic Substances Control Act (TSCA) for 107 chemical substances that were the subject of premanufacture notices. Eight of the chemicals are also subject to TSCA consent orders issued by EPA. The rule is effective on November 20, 2012.

Under the new SNURs, anyone who intends to manufacture, import, or process any of the listed 107 chemical substances for any activity that EPA designates as a significant new use must notify EPA at least 90 days before beginning the activity. EPA will, in turn, evaluate the intended activity, and, if necessary, prohibit or limit the activity before it occurs.


Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs.
For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

 

Proposed Safe Chemicals Act of 2011

The Safe Chemicals Act of 2011 (S. 847) was approved by the Senate Environment and Public Works (EPW) Committee on July 25 in a party-line vote. Introduced by Senator Frank R. Lautenberg (D-NJ), the legislation would modernize the Toxic Substances Control Act of 1976 (TSCA) and give EPA authority to require health and safety testing of toxic chemicals. The bill would place the burden on industry to prove their chemicals are safe. Currently, EPA can call for safety testing only after evidence surfaces showing a chemical is dangerous.

In brief, the Safe Chemicals Act would:

• Require manufacturers to develop and submit safety data for each chemical they produce, while avoiding duplicative or unnecessary testing.
• Prioritize chemicals based on risk, so that EPA can focus resources on evaluating those most likely to cause harm while working through the backlog of untested existing chemicals.
• Place the burden of proof on chemical manufacturers to demonstrate the safety of their chemicals.
• Restrict uses of chemicals that cannot be proven safe.
• Establish a public database to catalog the information submitted by chemical manufacturers and the EPA's safety determinations.
• Promote innovation and development of safe chemical alternatives, and bring some new chemicals onto the market using an expedited review process.

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

For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website 

 

Chemical Data Reporting CDR Submittal Deadline Extended

The Assistant Administrator for Chemical Safety and Pollution Prevention signed a final rule on June 11, 2012 which extended the submittal period of Chemical Data Reporting (CDR). Until this extension, CDR submittals were due on or before June 30, 2012. This change extends the submittal period to August 13, 2012.

CDR reporting requires that manufacturers, processors and/or importers of TSCA-regulated chemicals to report quantities manufactured or imported and certain other information regarding chemical manufacturing (including imports) and processing.

Read a summary of the CDR rule finalized in 2011.

Need technical assistance in determining what chemicals require reporting or help with the submittal process? Caltha LLP provides technical resources to meet the needs of large and small businesses around the county. For further information, contact Caltha at (763) 208-6430 or email your questions to info@calthacompany.com

ICR For TSCA Section 4 Testing Rules

US EPA has forwarded an Information Collection Request (ICR) to the White House Office of Management and Budget for review and approval. The agency is looking for more information on TSCA Section 4 test rules, consent orders, enforceable consent agreements, voluntary testing agreements, voluntary data submissions, and exemptions from testing requirements. The ICR covers the submission of test data to EPA to support the decision-making process for an industrial chemical under the Toxic Substances Control Act (TSCA). Under TSCA, EPA has the authority to issue regulations designed to gather health, safety, and exposure information on, require testing of, and control exposure to chemical substances and mixtures. Drugs, cosmetics, foods, food additives, pesticides, and nuclear materials are exempt from TSCA.

Under TSCA Section 4, EPA must assure that appropriate tests are performed on a chemical if it decides that a chemical being considered may pose an “unreasonable risk” or is produced in “substantial quantities that may result in substantial or significant human exposure or substantial environmental release of the chemical.” EPA also requires testing if additional data are needed to determine or predict the impacts of the chemical’s manufacture, processing, distribution, use, or disposal.

The Agency originally sought comments on the ICR in August, 2011. Additional comments may be submitted on or before May 25, 2012, using docket ID Number EPA-HQ-OPPT-2010-1010.


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.
For further information contact Caltha LLP at
info@calthacompany.com or Caltha LLP Website

History and Overview of New TCSA Chemical Data Reporting Rule

The EPA Chemical Data Reporting rule was finalized in November 2011, and the reporting period is now open until June 30, 2012.

Below is a link to a brief history and summary of the CDR rule.

History and Overview of New TCSA Chemical Data Reporting Rule

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.

For further information contact Caltha LLP at

info@calthacompany.com or Caltha LLP Website

TSCA section 8(a) and TSCA section 8(d) Reporting Hydraulic Fracturing Chemicals

EPA has announced plans to develop an Advance Notice of Proposed Rulemaking (ANPRM) and initiate a stakeholder process to provide input on the design and scope of the TSCA reporting requirements for Hydraulic Fracturing Chemicals. This would include chemical information reporting under TSCA section 8(a) and health and safety data reporting under TSCA section 8(d). EPA anticipates that states, industry, public interest groups and members of the public will be participants in the stakeholder process.

No proposed schedule for the ANPRM was released.

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.

For further information contact Caltha LLP at

info@calthacompany.com or Caltha LLP Website

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