Certification Retention Requirements

The required language for the different types of certifications is set out earlier in this chapter. While there is no specific recordkeeping requirement under TSCA 12(b), TSCA generally requires that records be kept for five years.  

For TSCA purposes, TSCA import certifications should be kept for five years and any documents used in determining the compliance of the substance with TSCA (such as supplier certification letters, MSDS and the Kke) for five years from the date of last import of the product, since the company will be relying on those documents the entire time it imports the product, not just the first time. 

While EPA has the authority to prosecute importers and exporters for failure to comply with the requirements of TSCA 12 and 13, the Customs Service has the concurrent jurisdiction to detain inbound shipments not in comph-ance with 13. The Court in ALM v. U.S. E.P.AP upheld these co-existing, independent enforcement mechanisms, explaining that Customs may not be able to identify every non-complying shipment at the port because of the large volume of imports and the inefficiency and inconvenience of physical searches of every import by Customs Service officials. Depriving EPA of the 

For customs, tax, or other reasons, an importer may need to keep additional documentation for other time periods. 

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Switzerland has contributed to TECDOC-801 at the IAEA and has made a large scale contribution to the certification of SBWR by integral testing of passive systems for afterheat removal and fission product retention required by USNRC, done for General Electric. 

Does the system include the retention of calibration certificates or data used in support of all calibration of measuring equipment Does the record system allow for calling forward, at the appropriate interval, equipment requiring calibration ... 

Step 19. The ITS maintains required documentation in entry files according to the Company s record retention policy. TSCA certifications shall be maintained for five years. 

Subpart D is short and sweet. It has to do with what is required on a Driver Training Certificate and retention of the certificate. 

Driver compliance and retention procedures — These procedures should list the driver qualification documents subject to expiration that are required to be kept on file such as legible copies of the driver s license, motor vehicle record (MVR), and physical examination certificates. Also, a record as to when all hazardous materials refresher training is required must be kept. 

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