SGIA Submits Comments to EPA on Proposed TSCA Inventory Notification (Active-Inactive) Requirements

On March 14th, 2017, SGIA submitted comments to the Environmental Protection Agency regarding the proposed TSCA Inventory Reset rule. The proposed rule “resets” the Toxic Substances Control Act Chemical Substance Inventory, and provides procedures for classifying chemicals as either active or inactive. According to the proposed rule, substances listed on the TSCA inventory that were manufactured in or imported to the United States for non-exempt commercial purposes between June 21, 2006 and June 21, 2016 must report to the EPA. This retrospective notification is required for manufacturers and optional for processors. When EPA is notified of the manufacture, importing, or processing of a chemical substance, that substance is designated as active. Substances that the EPA does not receive notices for are designated as inactive. Once a substance becomes inactive, it is unlawful to manufacture, import, or process using that chemical. SGIA supports parts of the rule, such as not requiring processors to submit information. There were, however, other parts of the rule that SGIA was not able to support. As part of the reporting process, manufacturers are required to submit the exact dates that a product was manufactured or imported over the designated ten-year period. SGIA commented that this specific reporting requirement is unnecessary and that many businesses will not have that information. SGIA also commented in disagreement with the reporting requirements, which would give manufacturers the responsibility of retaining records of their submissions for five years. As EPA does not provide a basis for this requirement, SGIA requested that it be removed. SGIA also commented that the EPA should be lenient on businesses who unintentionally submit incorrect information or who do not have all the required information. SGIA recommended that the EPA encourage follow-up reporting rather than penalizing these businesses.  Sign up to receive the most up-to-date regulatory and legislative information about specialty imaging.
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