ENV-17-37 TSCA Reform – the Inventory Reset Rule

Description:

In June 2016, the long-awaited revision of the Toxic Substances Control Act (TSCA) of 1976 occurred! One of the new elements of the revised Act that will affect all petroleum refineries and chemical manufacturers is the TSCA Inventory Notification (Active-Inactive) Rule, which was published in the Federal Register on August 11, 2017. Manufacturers and importers will have 180 days after the issuance of the final rule to submit “active” notifications for chemical substances, while sites that process chemical substances will be able to submit notifications until 420 days after the issuance of the final rule. This paper summarizes the requirements of the TSCA Inventory Notification (Active-Inactive) Rule and the steps to take to fulfill this notification requirement. New provisions related to Chemical Data Reporting (CDR) are also discussed.