TSCA Compliance in 2020. Preparing for Chemical Data Reporting.

Background
The Toxic Substances Control Act (TSCA), originally signed in 1976 and administered by the United States Environmental Protection Agency (EPA), is intended to protect workers, consumers, and the environment from adverse chemical impacts.  TSCA houses an inventory of more than 86,000 chemical substances for which it provides risk evaluation and regulatory management.  In 2016, the Act was reformed to apply an enhanced risk-based process to inventory management.

TSCA’s chemical data reporting rule
TSCA contains several sections that define EPA’s regulatory authority, and regulated entities are subject to the chemical data reporting (CDR) rule.  This rule requires manufacturers, importers, and processors of chemical substances to provide information to EPA every four years.  The next CDR cycle is June 1, 2020 – September 30, 2020.

The CDR allows EPA to collect exposure-related information on chemical substances and make related information available to the general public.  The CDR represents the nation’s most comprehensive data set on chemical substances and their proposed uses, and EPA uses the data to assess potential human health and environmental impacts.

In April 2019, the EPA proposed these changes to the CDR: 

  • Update the definition of the "small entities" that are exempt from reporting
  • Add exemptions for some byproducts
  • Simplify reporting by allowing the use of existing Organization for Economic Cooperation and Development (OECD) processing and use data codes
  • Remove outdated content
  • Consolidate exemptions

The commenting period for the proposed CDR changes closed in June 2019 and a final ruling is expected in 2020.

Preparing for reporting success in 2020
EPA estimates that the proposed changes will result in an overall net decrease in reporting burdens, and further expects the changes to result in net cost savings.  As an example, the small entities definition change is expected to result in fewer industry sites having to report at all.

However, while the proposed changes may reduce reporting burdens over time, the fact that the proposed changes are likely to take effect close to the start of the 2020 CDR cycle means that regulated stakeholders will have to get up-to-speed on changes quickly. 

To prepare for a successful 2020 reporting cycle, be sure to: 

Contact us today
Trihydro has experience providing CDR services and can advise on company-wide TSCA compliance with reporting, recordkeeping, import/export, Active-Inactive rule requirements, allegations/substantial risk, and new product/use registrations.  Whether you have questions regarding the upcoming CDR changes, or want to discuss TSCA compliance as a whole, we can assist. 

Andrew Pawlisz, D.A.B.T
Senior Scientist
apawlisz@trihydro.com
(720) 399-2003

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Andrew Pawlisz, DABT
Andrew Pawlisz, DABT
Senior Toxicologist, Tulsa, OK

Andrew is a board-certified toxicologist with over 20 years of experience in risk assessment and evaluation; hazard assessment; and regulatory compliance, including the legacy and reformed Toxic Substances Control Act (TSCA). Andrew specializes in finding practical solutions to regulatory and human health/environmental issues related to toxicants.
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