The Office of Management and Budget received the final rule update for the Hazard Communication Standard (1910.1200) on 10/25/11. The 90 day review period is over but the review period has been recently extended.
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The Office of Management and Budget received the final rule update for the Hazard Communication Standard (1910.1200) on 10/25/11. The 90 day review period is over but the review period has been recently extended. 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. 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? “In our society and legal system it seems that, yes, someone (or many) has to tragically die before change and regulation are considered.” In this case, the tragedy was 343+2. 343 firefighters perished in the September 11, 2001 tragedy. Less than six years later, the lives of two additional NY firefighters were claimed during the demolition of the 9/11-damaged Deutsche Bank Building. These contributing conditions created by the asbestos abatement project have been recognized by several authorities, and in an effort to maximize safety, New York City enacted a number of new laws to ensure that asbestos abatement projects are conducted safely. 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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