EPA settled with Blaser Swisslube, Inc. for $150,000 for importing a chemical not on the TSCA Inventory for 2 1/2 years. This was discovered by an EPA Region 2 inspection.
Attention Formulators: CHECK ON THE TSCA INVENTORY STATUS OF ALL YOUR RAW MATERIALS!
- Domestically purchased chemicals are the prime responsibility of the manufacturer. The manufacturer will likely pay a hefty fine. But if they screw up, you lose your supply until they get back into compliance.
- Imported chemicals where you are responsible for Customs paperwork and duty, makes you directly responsible for TSCA compliance. You pay two fines for each day of import of an unlisted TSCA use chemical: false import certification (section 13 of TSCA that requires you certify compliance with or exemption from TSCA) and premanufacture notification failure (section 5 of TSCA).
EHS Strategies, Inc. can help you get into compliance with TSCA.
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