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Posts Tagged ‘CDR’

TSCA CDR Data Released

EPA news item:

“EPA has released the non-confidential Chemical Data Reporting (CDR) information on chemical manufacturing, processing and use in the United States.

The 2012 non-confidential database and search tool are available at www.epa.gov/cdr. Users can download the database or search the database by chemical name, CAS number, or company name to retrieve company and site-specific information about chemicals in commerce and to view information on specific uses of chemicals, such as those used in products intended for children. This website also includes more information about the CDR data results, as well as fact sheets.”

Interesting Fact Sheet on uses and reduction in CBI claims.  “The EPA received reports on 7,674 chemicals, including 354 that were reported as used in children’s products. 1,704 chemicals were reported as used in consumer products and 3,073 were used in commercial applications or products. The remaining chemicals reported were for industrial use only.”  Makes the scary 85,000 chemicals in commerce number that is used by NGOs look a little silly.  Also have to question whether some of the chemicals listed as being in children’s products were misclassified – gases propane and ethane? butane? ethyl benzene? These would be industrial intermediates at most and not used by children.

Make sure your reports are correctly represented.

Contact EHS Strategies, Inc. for help.

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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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TSCA CDR: Webinar on CDX e-Reporting

On February 8, 2012 from 1:30 to 3:30 EST EPA will conduct a webinar on CDX Registration for the CDR Rule. Discussions will include registration for the 2012 CDR, and how to access eCDRweb, the electronic reporting tool needed to complete the CDR Form U. There will be time for questions. Register for the webinar.

If you already do TRI on CDX, this shouldn’t be a big deal.

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TSCA CDR Update – FAQs & Byproducts

EPA has posted FAQs on the Chemical Data Reporting rule here.  Companies can now access the electronic reporting tool, CDX for the rule: here

A meeting was held January 19, 2012, with EPA trying to explain how CDR applies to byproducts:

Some good news:  EPA is backing off of recycling as manufacture requiring reporting.  As long as all you are doing is separating out (e.g., distilling) a raw material or product (refining) you don’t have to report.  Refining and processing a chemical product further to remove impurities is not reportable.  Only if you extract or create a substance by chemical reaction do you have a reporting responsibility.  Bottom line:  A chemical has to have been manufactured by you; a change in CAS# has to have occurred.  Solvent recyclers are off the hook!

Muddled further is the situation with impurities that are created by your chemical reactions and how your chemical products, co-products and byproducts are described by CAS#.  Are they mixtures of known discrete chemicals or UVCB?  It sounded like EPA was saying that it doesn’t matter if a substance is an impurity – if produced by chemical reaction, the only way to avoid CDR reporting as a manufacturer is to meet one of the exemptions: <25,000 lbs, polymers, burned as fuel, TSCA exempt use, disposed.  Another CDR exemption is if the chemical isn’t on the TSCA Inventory.  Of course, if the byproduct is not otherwise exempt and it’s not on the TSCA Inventory – because everyone considered it to be a non-reportable impurity – you may have a PMN violation.

EPA seemed to be trying to avoid problems it had created in its earlier guidance by considering products and byproducts as mixtures, where the unwanted byproduct components get used in exempt ways or disposed and so don’t require reporting.

The webinar and materials will be posted shortly.

Congressmen Shimkus and Upton are asking EPA to extend CDR some more since there is still confusion.  This webinar only confirmed that. http://www.bna.com/upton-asks-epa-n12884907277/

 
EHS Strategies, Inc. will be tracking this issue and can assist you.

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