ENV-09-14 Understanding the Proposed TSCA Inventory Reset and Preparing for the Next TSCA Reporting Cycle

Description:

The Environmental Protection Agency (EPA) is proposing to reset the Toxic Substances Control Act (TSCA) Chemical Substances Inventory to remove outdated chemicals, resulting in a streamlined list containing only the chemicals currently in commerce in the United States. Unfortunately, the removal of a chemical from the list eliminates the authorization for any production of that chemical. If a company proposes to manufacture/import or process a chemical that is no longer on the TSCA Inventory list or has never been on the list, then a company must submit a premanufacture notification (PMN) to the EPA, and then wait for approval. This paper addresses the impact of the TSCA Inventory Reset with a focus on why the refining industry should be concerned. The second topic covered in this paper is the upcoming TSCA Inventory Update Reporting (IUR) cycle. The next reporting cycle will address chemicals manufactured during calendar year 2010; therefore, tracking of chemicals must begin in January 2010. The steps that should be taken to prepare for the TSCA IUR cycle are identified and discussed.