20
Jun
2013
EPA has released a Fact Sheet on reporting isotopes for the TSCA Inventory out of the blue. They are coy about whether failure would result in penalties. You should contact EPA for a prenotice PMN review sometime within a year and maybe you’ll be let off the hook. Apparently, EPA lost an administrative law case way back in 1997 because it didn't have enough background published on the issue. Someone must have raised the issue with them.
Medical use and R&D only exemptions still apply, so there likely aren't many who are subject to PMNs on isotopes, but you never know....
Contact EHS Strategies, Inc. if you need help.