Search

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.
 
History
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

Find a Post

Compliance Archives

Lion - Quotes

I can't say enough how pleased I was with this course! Everything finally makes sense.

Kim Graham

Lab Manager

Lion Technology workshops are amazing!! You always learn so much, and the instructors are fantastic.

Dorothy Rurak

Environmental Specialist

As always, Lion never disappoints

Paul Resley

Environmental Coordinator

These are the best commercial course references I have seen (10+ years). Great job!

Ed Grzybowski

EHS & Facility Engineer

Much better than my previous class with another company. The Lion instructor made sense, kept me awake and made me laugh!

Marti Severs

Enterprise Safety Manager

This course went above my expectations from the moment I walked in the door. The instructor led us through two days packed with useful compliance information.

Rachel Stewart

Environmental Manager

Best instructor ever! I was going to take my DOT training w/a different provider, but based on this presentation, I will also be doing my DOT training w/Lion!

Donna Moot

Hazardous Waste Professional

I like Lion's workshops the best because they really dig into the information you need to have when you leave the workshop.

Tom Bush, Jr.

EHS Manager

Excellent course. Very interactive. Explanations are great whether you get the questions wrong or right.

Gregory Thompson

Environmental, Health & Safety Regional Manager

The instructor was excellent. They knew all of the material without having to read from a notepad or computer.

Gary Hartzell

Warehouse Supervisor

Download Our Latest Whitepaper

Hazardous materials shipment rejections bear a big cost. Use this guide to end operational and logistical disruptions that severely impact your bottom line.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.