Toxic Substances Control Act Hits “Reset”
In 2013, Congress initiated reform of the Toxic Substances Control Act (TSCA) with the introduction of the Chemical Safety Improvement Act (CSIA).  Changes resulting from the reform are expected to be finalized very soon – on June 22, 2017.  While the reform affects many aspects of the TSCA regulations, the most pressing and pertinent items that will require immediate action from manufacturers, importers, and processors (optional) are related to the TSCA Inventory Reset.

What is Required?
Once the final rule is published, manufacturers and importers will have 180 days to electronically submit, via the EPA Central Data Exchange (CDX), an “active” list of chemical substances to be accounted for in the Inventory Reset.  This list must include data from June 21, 2006, through June 21, 2016.  Because of current Chemical Data Reporting (CDR) requirements, gathering the required data for years 2010 through 2016 should be straightforward.  However, locating and compiling the correct data for years 2006 through 2009 may be more burdensome, as documents from this timeframe may not have been retained.

Moving Forward
Once the TSCA Inventory is updated, manufacturers and importers will need to closely track the chemical substances they are manufacturing/importing for commerce in order to check that their substances are listed as “active” in the Inventory.  If a chemical substance is “inactive,” EPA will require a 30-day advanced notification before any activity can occur involving an “inactive” substance.

If you need any assistance compiling and submitting your active list of chemical substances prior to the December 19, 2017 due date, or would like a better understanding of the recent TSCA regulation revisions, please contact Becca Bradley, Project Engineer ([email protected]) or Jay Christopher, Senior Air Specialist ([email protected]).

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