Chemicals on Report Rules

Exporters are also required to notify EPA before shipping any product abroad for which test data are required, regulatory action has been proposed or occurred, or action of some sort is pending or relief granted. Substances subject to export notification are listed on the Chemicals on Reporting Rules (CORR). 

For a listing of toxic substance categories as defined within the Chemicals on Reporting Rules database, access https //www.unh.edu/ehs/pdf/TSCA-CORR-By-CAS.pdf. 

Chemicals on Reporting Rules (CORR), a database of about 7500 regulated compounds prepared by the Environmental Protection Agency (Ref 5)... 

Environmental Protection Agency, Chemicals on Reporting Rules, . 

A completed Form R must be submitted for each toxic chemical manufactured, processed, or otherwise used at each covered facility as prescribed in the reporting rule in 40 CFR Part 372 (published February 16,1988 in the Federal Register). These instructions supplement and elaborate on the requirements In the reporting rule. Together with the reporting rule, they constitute the reporting requirements. All references in these instructions are to sections in the reporting rule unless otherwise indicated. 

EPA proposed and reproposed its Section 8(d) rule and CMA submitted extensive comments. CMA expressed concern that the proposal applied to a broad and indiscriminate selection of chemicals with little attempt to explain why reporting on these chemicals is needed. The legislative history and Sections 2 and 9 of TSCA require EPA to minimize the burden on reporters by seeking only information necessary to achieve its objectives under TSCA. Many of CMA s concerns were addressed by EPA in the final Section 8(d) rule published in September. 

American Chemistry Council (ACC), Guide to the Business of Chemistry, 2004 Fermont, M., Changing rules, European Chemical News, 2004, July, Newsletter 13 L. Hepner Associates, cited according to L. Jarvis, Vitamin C Prices Flit New Lows on Chinese Imports, Chemical Market Reporter, 2004, June 14... 

A9.6.4.4 The U.S. EPA has recently posted a draft document on its website Development of Chemical Categories in the HPV Challenge Program, that proposes the use of chemical categories to voluntarily compile a Screening Information Data Set (SIDS) on all chemicals on the US HPV list. .. [to provide] basic screening data needed for an initial assessment of the physicochemical properties, environmental fate, and human and environmental effects of chemicals (US EPA, 1999). This list consists of ...about 2,800 HPV chemicals which were reported for the Toxic Substances Control Act s 1990 Inventory Update Rule (lUR) . 

Data from case reports and surveys are useful, but concomitant exposure to other chemicals cannot be ruled out, and exposure concentrations and durations are rarely known. Although the actual levels of exposure that produced death are not known for any of these cases, some investigators used simulations to estimate the fatal exposure concentrations. Droz et al. (1982) performed detailed simulations of two fatalities from intentional 1,1,1-trichloroethane inhalation. The lethal concentration of 1,1,1-trichloroethane was estimated to be between 6,000 and 14,000 ppm in one case and between 10,000 and 20,000 ppm in the other. Simulation of the circumstances of deaths of two people exposed while using 1,1,1-trichloroethane as a solvent showed that concentrations < 6,400 ppm may have been generated in one case (Jones and Wnter 1983), and concentrations < 9,000 ppm may have been generated in the other (Silverstein 1983). Northfield (1981) reported a case in which a worker, whose death was attributed to respiratory failure, may have been exposed to 1,1,1-trichloroethane concentrations of 6,000 ppm or higher, depending on distance from the source. 

The Toxic Substances Control Act (TSCA)i called for the creation of a massive list of all the chemicals in commerce in the United States. The list is the TSCA Inventory, or more simply, the Inventory. To compile the Inventory, the United States Environmental Protection Agency (EPA) issued an Inventory Reporting Rule in 1977 requiring companies to report all the chemicals they had manufactured or imported in the previous three years, and the result was inclusion of approximately sixty-two thousand chemicals on the Inventory. Since that time, over twenty-one thousand more chemicals have been added to the Inventory." ... 

The information to be included on the form is intended to gather very preliminary exposure data to permit the Agency to assess testing priorities.i When promulgated in 1980, PAIR was intended by EPA to be the first of a series of progressively more detailed reporting rules under TSCA 8(a) to establish a comprehensive assessment of chemical substances."... 

Once a chemical substance or mixture is added to the rule, the reporting period typically terminates sixty days after the effective date of the listing. Importers who bring chemicals into the United States as part of articles are subject to TSCA 8(d) reporting rules. The 8(d) rules apply to importers and the definition of importer includes any person who brings a chemical substance into the U.S. as part of a mixture or an article. The EPA s call for health and safety data on lead in children s toys is an example of an 8(d) rule that clearly is intended to include importers of chemical substances in articles. In the preamble to that rule, the EPA said ... 

TSCA 12(b) violations are assessed per chemical per country, either per year if the notification requirement is an annual one, or only for the first required export per country if the notification requirement is not an annual requirement. Except for the variable violation, 13 violations are assessed one violation per chemical per day, regardless of the number of shipments or the number of ports through which a chemical enters on the same day. In the Reporting Rule ERP, EPA gives several examples of how to determine the number of violations based on the number of shipments. For example, it explains that if the same chemical is imported on the same day to one or more ports in three separate shipments, there is one violation. If the same chemical is imported once a week over a period of five weeks, there are five separate violations, one for each day in which there was an import. If six different chemicals are imported in six separate shipments on the same day, six separate violations would be assessed, one for each chemical in a different shipment. However, if two or more chemicals are imported on the same day in only one shipment, then only one violation would be assessed. ... 

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