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TSCA Chemical Data Reporting: The New Form U and You

Posted on 1/10/2012 by James Griffin

On August 16, 2011 (76 FR 50816), EPA published its new Chemical Data Reporting (CDR) Rule, replacing the previously existing Inventory Update Report (IUR) Rule. While the form for submitting data remains the same (the Form U), some key information has changed.
In 1978, EPA compiled what is now known as the TSCA Master Inventory. In addition to mechanisms for adding new chemicals to the inventory (a subject for another time), EPA also requires manufacturers and importers to periodically submit specific information about substances on the inventory, including recent publications and site data, to better track the presence of these chemicals in the marketplace.
Between 1978 and 2006, EPA amended the Inventory Update Rule a number of times. In 2011, EPA considered making some major changes. The result was a delay in the announced reporting due date. Originally, data on 2010 production was due in mid-2011, but EPA told sites subject to the IUR to hold off on data submission until the new rule was finalized.
What’s the difference between the IUR and the CDR?
 The August 16, 2011 rule did more than just change the name of the reporting requirement. It also changed:
  • The location of the regulations. The IUR rules were in 40 CFR 710. The CDR rules are in 40 CFR 711.
  • The frequency of reporting. The IUR was on a five-year cycle. The CDR is a 4-year cycle. The current report is due in 2012 and the next reporting year will be 2016.
  • The submission period. Instead of the usual June 1 through September 30 period, the report is due between February 1 and June 30, 2012. (The June—September period will be reinstated for the 2016 report.)
Who is subject to CDR?
“For the 2012 submission period, any person who manufactured (including imported) for commercial purposes 25,000 lbs. (11,430 kg) or more of a chemical substance [on the inventory] at any single site owned or controlled by that person during the principal reporting year (i.e., calendar year 2011) is subject to reporting.” [40 CFR 711.8(a)]
Will there be more changes?
In addition to returning the submission period to June through September for the 2016 reporting year, there will be other changes. For 2016, any person who manufactured 25,000 lbs. or more of a chemical substance on the Inventory in ANY calendar year since the previous reporting year will have to submit the Form U in 2016.

Tags: EPA, reporting and recordkeeping, TSCA

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