Search

TSCA CDR Reports Due September 30!

Posted on 9/13/2016 by Anthony Cardno

Update 09/19/16: US EPA has extended the deadline for submitting TSCA Chemical Data Reports from September 30 to October 31, 2016.

The Toxic Substances Control Act (TSCA) requires the Environmental Protection Agency (EPA) to collect information from chemical manufacturers and importers via the Chemical Data Reporting (CDR) program. The requirements for reporting are found at 40 CFR 711. In December of 2015, we wrote about some of the major changes to the TSCA CDR requirements. With the window to submit Chemical Data Reports closing on September 30, 2016, now is a good time to review how to report—and what's changed since our last update.

TSCA CDR Reporting Thresholds


The reporting threshold is 25,000 lbs. or greater. If a site manufactured or imported 25,000 lbs. or more of a chemical in any calendar year from 2012 through 2015, that site is subject to the reporting requirements.

For certain chemical substances, a lower threshold of 2,500 lbs. triggers the reporting requirements. This lower threshold applies to any chemical substance subject to any of the following TSCA actions:
  • A rule proposed or promulgated under TSCA §§5(a)(2), 5(b)(4), or 6;
  • An order issued under TSCA §§5(e) or (f); or
  • Relief that has been granted under a civil action under TSCA §§5 or 7.
The EPA now allows manufacturers and importers to utilize the Substance Registry Services (SRS) to more easily identify chemicals that are the subjects of the above-listed actions. Instructions on how to utilize the SRS in connection with the e-CDR reporting program can be found here. Both of these thresholds are chemical- and site-specific. In other words, you do not add different chemicals together to see if you've hit the threshold, nor do you add together volumes of the same chemical manufactured at two different sites.


Submitting Your 2016 CDR


Once a site is subject to the CDR requirements, regardless of which threshold is triggered, the site must submit the following information:
  • Total annual production and use information for all four years (2012–2015)
  • Processing and use information only for the principal reporting year (2015)
All of this information must be reported electronically on Form U, using the e-CDR reporting tool via the EPA's Central Data Exchange (CDX) portal. EPA no longer accepts paper submissions. You can find a sample of the current Form U on EPA's website.

Partially Exempt Chemicals


While the TSCA reporting rules address an enormous variety of chemicals, there are exceptions. EPA maintains a group of chemicals for which reporting process and use information is not required—even if a facility hits the appropriate threshold in a given year.

The list can be found at 40 CFR 711.6(b)(2)(iv). Chemicals are placed on this list if EPA feels there is "low current interest" in the processing and use information on those chemicals.

On March 29, 2016, the EPA added six new chemicals to this list. The newly added chemicals are:
  • Fatty acids, C14-18 and C16-18 unsaturated, methyl esters (Chemical Abstract Services Registry Number (CASRN) 67762-26-9)
  • Fatty acids, C16-18 and C-18 unsaturated, methyl esters (CASRN 67762-38-3)
  • Fatty acids, canola oil, methyl esters (CASRN 129828-16-6)
  • Fatty acids, corn oil, methyl esters (CASRN 515152-40-6)
  • Fatty acids, tallow, methyl esters (CASRN 61788-61-2)
  • Soybean oil, methyl esters (CASRN 67784-80-9)

What Does EPA Do With the Information Collected?


The information EPA collects under the CDR is available to be searched online. In the previous CDR reporting year, EPA collected information on 7,690 different chemicals. A full alphabetical listing of the chemicals EPA received information about in 2012 can be found here. And a summary of EPA's findings can be found here.

TSCA Training for EHS Professionals


Need to know more about TSCA CDR reporting? Join us for the live, instructor-led TSCA Chemical Reporting & Recordkeeping Webinar on October 20. We'll cover the latest changes to the TSCA CDR requirements, as well as other critical TSCA reporting programs like Significant New Use Rules (SNUR), import certifications and export notifications, Premanufacture Notifications (PMN), recordkeeping for Health and Safety Data, and more.

Want training you can take anytime? The TSCA Regulations Online Course walks you through the major elements of US EPA's Toxic Substances Control Act to help you ensure your chemical management and reporting procedures meet EPA's stringent requirements. Learn how to handle, manage, and store chemicals-including PCBs-in line with the latest TSCA rules.

Tags: TSCA

Find a Post

Compliance Archives

Lion - Quotes

The course is well thought out and organized in a way that leads to a clearer understanding of the total training.

David Baily

Hazmat Shipping Professional

Lion is at the top of the industry in compliance training. Course content and structure are updated frequently to make annual re-training enjoyable. I like that Lion has experts that I can contact for 1 year after the training.

Caroline Froning

Plant Chemist

If I need thorough training or updating, I always use Lion. Lion is always the best in both instruction and materials.

Bryce Parker

EHS Manager

Excellent. I learned more in two days with Lion than at a 5-day program I took with another provider.

Francisco Gallardo

HES Technician

Well designed and thorough program. Excellent summary of requirements with references. Inclusion of regulations in hard copy form, as well as full electronic with state pertinent regulations included is a great bonus!

Oscar Fisher

EHS Manager

One of the best trainings I have ever received!

Brandon Morfin

EH&S Manager

Lion was very extensive. There was a lot of things that were covered that were actually pertaining to what I do and work with. Great Job. I will be coming back in three years!

Tony Petrik

Hazmat Shipping Professional

The instructor was very patient and engaging - willing to answer and help explain subject matter.

Misty Filipp

Material Control Superintendent

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

Ed Grzybowski

EHS & Facility Engineer

The instructor's energy, enthusiasm, and knowledge of the subject make the class a great learning experience!

Brian Martinez

Warehouse Operator

Download Our Latest Whitepaper

This report details major changes for hazardous waste generators from US EPA’s Generator Improvements Rule, as well as the latest updates from states that are still working to adopt new, stricter Federal requirements.

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.