Substantial risk reporting environmental effects

The discovery that chemicals that are known to have adverse effects are widespread in environmental media is reportable under 8(e). There must be more to a study than simply finding a substance associated with a substantial risk in the environment before the study becomes reportable. The distribution in the environment must have been not only imknown but also unsuspected and previously considered unlikely, and there must also be a... 

As discussed in Chapter 7, Reporting and Recordkeeping, 8(e) of the Toxic Substances Control Act (TSCA) requires that any person who imports, manufactures, processes, or distributes chemical substances or mixtures in the United States and who obtains information generated in the United States or in another country that reasonably supports a conclusion that a chemical substance or mixture may present a substantial risk of injury to human health or the environment must immediately report such information to the United States Environmental Protection Agency (EPA), unless the person knows that EPA has already been adequately informed. The information must be submitted to the Agency within thirty calendar days of the individual or business obtaining the information. For information to be reportable under 8(e), it does not need to establish conclusively that a risk exists and does not need to provide evidence that the substance is hazardous to human health or the environment under actual conditions of use and exposure. The information may relate to actual instances of serious human health or environmental injury caused by the chemical or mixture or to observations that are early indications of such effects. Incidents of environmental contamination may also be report-able under TSCA 8(e) and should be reviewed under this procedure in order to determine its immediate reportability as soon as the Company has knowledge of the incident. 

Section 8 The US EPA can request data on the properties, manufacture, exposure, and health and environmental effects of existing chemicals. Companies must keep records of adverse effects from their chemicals on health or the environment. Notably, under Section 8(e), responsible parties must report information that reasonably supports the conclusion that a substance or mixture presents a substantial risk of injury to health or the environment. 

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