TSCA Chemical Data Reporting rule (formerly IUR) Responses to Comments Summary on byproducts are precious. See F.3.e-3 and 4 on recovery and recycle of raw materials. Hope you have continuous closed processes!

And then there’s this one:

“Response F.3.f-1: EPA is aware that there may be situations where a company identifies a way to recycle or otherwise bring into commerce a byproduct chemical substance that is not listed on the TSCA Inventory because it has traditionally been treated as a waste or in such a manner that it has been otherwise exempted from listing on the TSCA Inventory and/or reporting under IUR. Manufacturers in such situations should contact EPA for help in properly identifying the byproduct and to determine whether it should be added to the TSCA Inventory.”  And talk to the Office of Enforcement maybe….
See docket EPA-HQ-OPPT-2009-0187-0436 pdf page 86

Write a rule for processor reporting, EPA, and quit enlarging the definition of "manufacture"  beyond recognition.
Contact EHS Strategies, Inc. to figure out what CDR means to your company.

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