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Archive for the ‘TSCA’ Category

SNURs: TSCA Notifications Multiply

EPA is on a tear issuing Significant New Use Rules (SNURs) under TSCA.  Mostly for new chemicals that hit triggers under PMN reviews.  Make sure you are reading notifications from suppliers – often on MSDS – that may affect how you can use the chemical (e.g., workplace protections and disposal restrictions) and trigger export notifications to EPA under section 12.

Watch the Federal Register! Recent notices here and here

Contact EHS Strategies, Inc. for help with SNURs

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TSCA CFR Bookmarks Updated

Updated TSCA e-CFR (electronic Code of Federal Regulations) links can be found on EHS Strategies, Inc.’s webpage TSCA Quick Links.  The Government Printing Office seems determined to move around the urls for TSCA.

Even EPA can’t keep up with the changes on their websites!  EPA’s page on section 8(d) health and safety studies reporting links 40 CFR 716 to

PART 407—CANNED AND PRESERVED FRUITS AND VEGETABLES PROCESSING POINT SOURCE CATEGORY

(which happens to be TSCA exempt)

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TSCA e-Reporting Webinars by EPA

EPA is presenting two webinars on the use of the TSCA electronic tools for section 8(a) (PAIR), 8(d) and 8(e)/FYI proposed reporting:

  • Rescheduled to September 18, 2012, from 1:00 – 3:00 p.m. Join a walk through on the CDX registration process and the 8(a) and For-Your-Information [not- 8(e) submissions] reporting tools. Time will be allotted for questions related to the reporting tool. Questions related to specific reporting requirements will not be covered during this webinar. Access the webinar.

An operator assisted conference call is required for this session (866-900-8984 webinar ID 26430193). Please try to register and dial in at least 10 to 15 minutes before the start of the webinar.

  • On September 20, 2012, from 1:00 – 3:00 PM EDT, join a refresher presentation on the CDX registration process and the 8(d) and 8(e) reporting tools. Time will be allotted for questions related to the reporting tool. Questions related to specific reporting requirements will not be covered during this Webinar. Access the webinar.

An operator assisted conference call is required for this session (866-900-8984 webinar ID 26429450). Please try to register and dial in at least 10 to 15 minutes before the start of the webinar.

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TSCA IUR/CDR Enforcement

EPA press release:

The reporting deadline for the 2006 IUR rule ended in March of 2007. EPA’s enforcement efforts have led to 43 civil enforcement actions and approximately $2.3 million dollars in civil penalties against companies that failed to report required chemical data information. The reporting deadline for the 2012 submission period of the Chemical Data Reporting Rule is August 13, 2012.

The three most recent cases are against Chemtura Corporation, Bethlehem Apparatus Company, and Haldor Topsoe, Inc., and resulted in penalties totaling $362,113.

Details here

Deadline for CDR is August 13, 2012.  Hurry up!
EHS Strategies, Inc. can help.

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Canada periodically puts out mandatory survey on batches of chemicals as it works through its prioritization process. For example in June there were 8 MDA/MDI chemicals of interest.  It’s a pretty comprehensive set of information demanded of manufacturers, importers and processors: volumes, uses available toxicity information and a list of the top 20 customers.  With the possible exception of getting customer lists, such information can be obtained under TSCA section 8 – basically CDR + 8(d) – applied to manufacturers, importers and processors.  

But note that Canada is only going after EIGHT chemicals in this notice – not thousands at a time like EPA does under CDR!  As Canada identifies categories of chemicals they are concerned about, they hold webinars and issue “mandatory surveys” – evaluate the information and go back for more if they need it (link).  Granted, they have far fewer companies and chemicals to cope with than the US, but note how they are being systematic about working through their inventory on a priority basis.

Maybe advocates for TSCA Reform are right – EPA needs the kick in the pants of legislative instructions to actually do something under TSCA.  The trouble is pick-a-number is pretty arbitrary.  But maybe that’s where we are at?  The Agency has had numerous initiatives – like ChAMP, HPV, Chemical Action Plans and now a “Work Plan” – but they always seem to run out of gas.  I still hold there is a ton of authority in the current TSCA for EPA to take action – especially if they tackle chemicals by category (section 26) and not try to do humungous every-test-known-to-man and/or ban-it-all regulations.

I’d certainly recommend looking to Canada as opposed to Europe as a model to emulate.

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CDR: One Month to Go

The Chemical Data Reporting (CDR) rule submissions are due in one month: August 13, 2012.
Don’t put it off until the last minute.  Rumors abound about how the eCDR CDX system is not the most robust in the world.  I can imagine periodic downtimes that last week as everyone scrambles to submit forms.
Contact EHS Strategies, Inc. for help.

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TSCA CDR Extended AUG 13, 2012

CDR due date has been extended to Aug 13, 2012. official notice


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