Here is a handy table we recently created for our clients — a gentle reminder to get organized! Even if you miss a deadline, it’s better to start playing catchup as soon as you find out that you are not in compliance.
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Here is a handy table we recently created for our clients — a gentle reminder to get organized! Even if you miss a deadline, it’s better to start playing catchup as soon as you find out that you are not in compliance. What are the basic criteria needed to support a confidentially claim on the 2012 CDR Submission? Any business with a trade secret or confidential chemical formula is definitely wondering about this very issue as they consider just how to file their 2012 CDR Form U. The EPA has increased the requirements (as in, made it more challenging) for companies who want to justify a claim of Confidential Business Information (CBI) in their CDR submission. The EPA hosted a 3-hour webinar on November 16, 2011 that reviewed the reporting process for the 2012 Chemical Data Reporting (CDR) Rule with a focus on joint reporting, considerations related to the reporting of byproducts, and updated information about registering for electronic reporting and for using the electronic reporting tool/ The EPA has posted the presentation slides online and expects to have a recording of the webinar available for viewing by December 1. Emilcott’s EPA webinar Take Aways are listed here. The TSCA CDR Rule includes specific information that addresses reporting for chemicals that are toll manufactured: The definition of “manufacture” includes a description of the issue of toll manufacturing or “co-manufacturing” (40 CFR 711.3 Definitions). If So, Company A contracts with Company B to manufacture more than 25,000 lbs of a CDR-reportable chemical in 2010 and 2011, which company should report the chemical substance on their 2012 CDR submission? TSCA questions are pouring in and we are responding. To ensure that the information is available in a reasonable (and non-overwhelming) way, Emilcott has created a TSCA resource section of our web site for centralizing all kinds of intelligence, notifications, links, and summaries about Toxic Substance Control Act (TSCA) 2012 Chemical Data Reporting (CDR). Read below and click on the links to learn more. If you are a foreign or domestic business in the US who is either a chemical importer (resells for use in blending, repackaging) or chemical manufacturer (make new chemicals out of chemicals purchased from others with the exception for pharmaceutical companies) or a chemical exporter, this update is about mandatory compliance with the EPA’s Toxic Substances Control Act (TSCA), specifically filing the 2012 TSCA Form U “Chemical Data Report”. Emilcott’s “take aways” regarding the EPA’s Sept 23 webinar about the 2012 CDR reporting requirements and the use of the electronic Form U reporting tool (“e-CDRweb”) are included in this blog entry. We just had our first cold weather snap in the northeast reminding me that 2012 is just around the corner. A change in the seasons is our cue to ask Emilcott clients that manufacture or import chemicals: Have you gathered the 2010 chemical volume data AND are you collecting the 2011 data needed for the 2012 TSCA Chemical Data Report? by Paula Kaufmann Upcoming TSCA Reporting Period: February 1 – June 30, 2012. As of August 6, the EPA has finalized the TSCA IUR — now named the Chemical Data Reporting (CDR) – Rule. There are many changes with the TSCA IUR to CDR … some of these will be in place for the 2012 reporting submission and many more for the 2016 submission. Read more for a complete update. Now that EPA has scheduled the submission period and defined what has to be reported, and how it must be done, Emilcott’s EHS group is compiling a centralized, online resource to help our clients complete the reporting process accurately and on time including email summaries of the revised requirements and critical changes to the 2012 Form U submission, notification of EPA seminars and other TSCA-related activities and free, informational TSCA-related webinars. |
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