WHAT TO EXPECT: REFORMED TSCA REQUIREMENTS FOR THE 2020 CDR

CDR is an information gathering mechanism under TSCA Section 8(a) used by the Environmental Protection Agency (EPA) to manage the manufacturing and importation of large volume chemicals that have the potential to adversely impact human health and the environment.  CDR reporting is a regulatory compliance requirement for many United States manufacturers and importers, but it is often overlooked because of its quadrennial reporting cycle.  Moreover, staff trained specifically on TSCA CDR frequently transition into new roles between reporting years and replacements are often not in place until just before the next regulatory due date.  A lot can change in the four years between reporting due dates, and institutional knowledge and required data can get lost in the shuffle.  

Unlike the last cycle in 2016, the 2020 CDR will occur under the reformed TSCA.  To make things even more complex, this reporting cycle will also be performed under the recently amended CDR rule.  Organizations need the understand the final CDR rule requirements to correctly complete the 2020 CDR.  With the CDR reporting season opening on June 1, companies may want to review several rule changes.

The EPA estimates the proposed changes will result in an overall net decrease in reporting burdens, including costs.  As an example, the small entities definition change is expected to result in fewer industry sites having to report. 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. 

This presentation is designed to help you organize and prioritize your reporting preparations and is available to be presented as a webinar or can be viewed on-demand via Trihydro’s website.

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