Life Cycle Thinking Blog

EPA news item:

EPA has released the non-confidential Chemical Data Reporting (CDR) information on chemical manufacturing, processing and use in the United States.

The 2012 non-confidential database and search tool are available at www.epa.gov/cdr. Users can download the database or search the database by chemical name, CAS number, or company name to retrieve company and site-specific information about chemicals in commerce and to view information on specific uses of chemicals, such as those used in products intended for children. This website also includes more information about the CDR data results, as well as fact sheets.

Draft risk assessments have been announced by EPA under their new Work Plan to begin tackling 83 chemicals. These are open for public comment and will be peer-reviewed. EPA may or may not take action to restrict uses under TSCA after the assessments are completed. In the meantime, the press release says:

“EPA recommends the public follow product label directions and take precautions that can reduce exposures, such as using the product outside or in an extremely well ventilated area and wearing protective equipment to reduce exposure.”

– even though the draft risk assessment says there is no concern for ATO and HHCB.

As expected, the direct final rule requiring reporting “health and safety studies” under TSCA 8(d) for anything with cadmium in it was too controversial.

EPA has withdrawn this final rule as of Dec 14, 2012 – too controversial!

ATTENTION ARTICLE MAKERS!

EPA today released a final rule that requires reporting of “health and safety studies” under TSCA section 8(d) for cadmium and its compounds in consumer products. This is a little broader than the lead rule that focused on children’s products (40 CFR 716.21(a)(8)).

EPA is on a tear issuing Significant New Use Rules (SNURs) under TSCA. Mostly for new chemicals that hit triggers under PMN reviews. Make sure you are reading notifications from suppliers – often on MSDS – that may affect how you can use the chemical (e.g., workplace protections and disposal restrictions) and trigger export notifications to EPA under section 12.

Updated TSCA e-CFR (electronic Code of Federal Regulations) links can be found on EHS Strategies, Inc.’s webpage TSCA Quick Links. The Government Printing Office seems determined to move around the urls for TSCA.

Even EPA can’t keep up with the changes on their websites! EPA’s page on section 8(d) health and safety studies reporting links 40 CFR 716 to

PART 407—CANNED AND PRESERVED FRUITS AND VEGETABLES PROCESSING POINT SOURCE CATEGORY

EPA is presenting two webinars on the use of the TSCA electronic tools for section 8(a) (PAIR), 8(d) and 8(e)/FYI proposed reporting:

Rescheduled to September 18, 2012, from 1:00 – 3:00 p.m. Join a walk through on the CDX registration process and the 8(a) and For-Your-Information [not- 8(e) submissions] reporting tools. Time will be allotted for questions related to the reporting tool. Questions related to specific reporting requirements will not be covered during this webinar. Access the webinar.

EPA press release:
The reporting deadline for the 2006 IUR rule ended in March of 2007. EPA’s enforcement efforts have led to 43 civil enforcement actions and approximately $2.3 million dollars in civil penalties against companies that failed to report required chemical data information. The reporting deadline for the 2012 submission period of the Chemical Data Reporting Rule is August 13, 2012.
The three most recent cases are against Chemtura Corporation, Bethlehem Apparatus Company, and Haldor Topsoe, Inc., and resulted in penalties totaling $362,113.

The Chemical Data Reporting (CDR) rule submissions are due in one month: August 13, 2012.
Don’t put it off until the last minute. Rumors abound about how the eCDR CDX system is not the most robust in the world. I can imagine periodic downtimes that last week as everyone scrambles to submit forms.
Contact EHS Strategies, Inc. for help.

CDR due date has been extended to Aug 13, 2012. official notice