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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.

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