ENV-11-34 Understanding the Delay and How to Comply with TSCA Chemical Data Reporting

Description:

On May 11, 2011, the Environmental Protection Agency (EPA) suspended the Toxic Substances Control Act (TSCA) Inventory Update Reporting (IUR) submission period, stating that the submission period will be postponed to provide time for companies to comply with the updated IUR requirements; however, significant opposition to the proposed revised reporting requirements had been expressed. Previously, in April 2011, the House Energy and Commerce Committee had urged the Office of Management and Budget to withdraw the proposed reporting modifications, claiming that the proposed rule failed to meet the requirements of the Paperwork Reduction Act and Executive Order 13563, and introduced “…needless new burdens on the U.S. economy.” This paper discusses the resolution of these issues and explains the revised IUR requirements, now designated as Chemical Data Reporting (CDR), with a focus on the refining industry. The chemical substances that are reported by refineries are reviewed, and steps to take to compile the data and prepare the reports are summarized.