Toxic Substances Control Act 2016 Chemical Data Reporting: Compliance for chemical manufacturers and importers of chemicals
Are you prepared?
Do you know if you are subject to the Toxic Substances Control Act (TSCA) Inventory Update, i.e., the Chemical Data Reporting Rule (CDR)? The CDR rule requires manufacturers and importers of chemical substances listed in the TSCA Inventory to report information about the manufacturing, importing, processing, and use of those chemicals. With our extensive experience, GHD can advise clients of the available options and how to best maintain compliance with CDR.
Am I subject to this reporting?
You may be subject to CDR reporting if you manufacture or import chemicals listed in the TSCA Inventory for commercial purposes in volumes of 25,000 pounds or more during each calendar year since the last principal reporting year. In a toll manufacturing arrangement, a company provides its raw materials or semi-finished goods to a third-party service provider. The service provider, who often has specialized equipment or infrastructure, provides a subset of manufacturing processes on behalf of the company using those materials or goods for a fee. In the most recent update to CDR, the definition of "manufacturer" was clarified under TSCA to include a person that contracts with another person, such as a toll manufacturer (as defined above), to manufacture a chemical substance. As such, they will be considered "co-manufacturers, and therefore, also responsible for compliance with CDR."
When is the CDR report due?
CDR requires facilities to report every 4 years, with the next reporting due between June 1, 2016, and September 30, 2016. Some of the information to be submitted includes company address and contacts, chemical substance identification (CA or CASRN number), production and/or import volumes, uses, number of commercial workers reasonably likely to be exposed for each commercial use identified, and claims for Confidential Business Information (CBI).
How do I submit CDR data to EPA?
All companies subject to CDR are required to report data using EPA's e-CDR web-based reporting tool. To utilize e-CDR, companies must first register with EPA's Central Data Exchange (CDX).
How can GHD help?
GHD's experienced staff is familiar with TSCA regulations and CDR reporting, and can assist companies in conducting a detailed CDR reporting applicability analysis as well as collect, organize, and report the data. Contact us to learn more about how GHD can assist with your TSCA CDR needs.