On June 18, 2012, the Federal Register published a Final Notice extending the reporting deadline for the revised TSCA Chemical Data Reporting Rule (CDR). The new deadline is August 13th, 2012, six weeks beyond the original deadline of June 30, 2012.
The purpose of CDR is for the EPA to collect quality, screening-level, exposure-related data on a wide range of chemical substances. But, who is subject to the rule and what are the requirements?
The answer is “it depends.” It depends on the reporting year. When EPA replaced the Inventory Update Rule (IUR) with the CDR, they decided to roll out the changes to ease the transition for manufacturers.
2012 Reporting Year
- Who: Anyone who manufactured (or imported) 25,000 lbs. or more of any chemical on the TSCA Inventory during the Principal Reporting Year (2011). The reporting threshold is chemical- and site-specific.
- What: The Form U must be used to submit full data on 2011 and manufacturing totals only on 2010.
- How: The EPA will only accept electronic submission of the Form U through its new e-CDRweb reporting tool, in conjunction with their Central Data Exchange (CDX).
2016 Reporting Year
- Who: Anyone who manufactured (or imported) 25,000 lbs. or more of any chemical on the TSCA Inventory in ANY year since the last PRY (in other words, in any of calendar years 2012 through 2015).
- What: The Form U will still be the required document, but facilities will be required to submit full data on 2015 and manufacturing totals for 2012, 2013, and 2014.
- How: The EPA will continue to require data be submitted electronically.
The Chemical Data Reporting rules are codified at 40 CFR 711. The EPA has more guidance on submitting your CDRs at its web site
What difficulties do you come across when filling out your chemical data reports?