Chemical compliance (TSCA)

The Toxic Substances Control Act (TSCA) gives the Environmental Protection Agency (EPA) the authority to regulate new and existing chemicals. Although initially passed in 1976, the Act was amended in 2016 to include updated provisions that require the EPA to evaluate existing chemicals in a timely fashion, outline new risk-based safety standards, increase public transparency on chemical substances and differentiate chemical risk evaluations based on whether they present a high or low risk. As a result, there are deadlines for manufacturers and importers of chemical substances to meet in 2018.

The Chemical Data Reporting (CDR) rule is a mandate under TSCA requiring manufacturers and importers of chemical substances that produce and use large quantities of chemicals to report information about the manufacturing, importing, processing and use of the chemicals every four years. This includes information on chemical substance production volumes, manufacturing site, and uses.

The EPA published the final rule establishing the process for the TSCA Inventory Reset on August 11, 2017. The final rule went into effect as of the same day because the deadline for manufacturers (includes importers) to submit retrospective reports under this rule is fixed by statute at “180 days after the date on which the final rule is published in the Federal Register.” Retrospective manufacturer reports are due no later than February 7, 2018.

TSG can help

  • Prepare Premanufacture Notices (PMN)
  • Assist with consent order negotiations
  • Prepare Significant New Use Notices (SNUN)
  • Make polymer exemption determinations
  • Prepare Low Volume Exemption applications (LVE)
  • Provide chemical import/export advice
  • Assist with chemical data reporting
  • Perform compliance audits and training
  • Prepare TSCA inventory NOA Form A and NOA Form B
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