Inventory Update Reporting , TSCA

TSCA 8(a) authorizes EPA to promulgate rules requiring manufacturers and importers of certain chemical substances and mixtures to maintain records and submit reports of production volumes, distribution, use, and human exposure under the Preliminary Assessment Information Rule (PAIR) and Inventory Update Reporting (lUR) Rule ... 

The U.S. HPV chemicals are those which are manufactured in or imported into the United States in amounts equal to or greater than 1 million pounds per year. The U.S. HPV chemicals were identified through information collected under the TSCA Inventory Update Rule (lUR). Organic chemicals that are manufactured in, or imported into, the United States in amounts equal to or exceeding 10,000 pounds per year are subject to reporting under the TSCA lUR. Reporting is required every 4 years. 

Fed. Reg. 21438 (June 12,1986) Partial Updating of TSCA Inventory Data Base Production and Site Reports Final Rule 51 FR 21438 lUR... 

EPA. 1998. Instructions for reporting for the 1998 partial updating of the TSCA chemical inventory data base. U.S. Environmental Protection Agency. Office of Prevention, Pesticides and Toxic Substances. EPA 749-B-98-001. 

Over 5,800 entries are included. Over 500 new entries were added. Some entries present in previous editions were removed to make room for more relevant substances and maintain the book at a reasonable size. Two-thirds of the entries have been revised for this edition. Most of the new entries were selected because they are on the EPA TSCA Inventory. These are reported to be used in commerce in the United States. Emphasis was placed on adding and updating physical properties and updating aU DOT Classifications. 

Fee-based resources include the updated US EPA Toxic Substance Control Act (TSCA) Chemical Inventory of 62,000 chemicals, which is available cross-referenced with Superfund Amendments and Reauthorization Act (SARA) Title III RCRA reporting requirements on CD-ROM. It features SARA III fields integrated with TSCA information and Adobe Acrobat (PDF) format for instant... 

A list of substances that were subject to TSCA actions at the time of the 2006 Inventory was contained in Appendix C to the Instructions for Reporting for the 2006 Partial Updating of the TSCA Chemical Inventory Database. (Nov. 2006) [hereinafter 2006 Instructions]. However. EPA makes clear in that Appendix that the Appendix is intended to be only an information resource. The list should not be relied upon in lieu of relevant orders. Federal Register documents, or the Code of Federal Regulations. 

Instructions for Reporting for the 2006 Partial Updating of the TSCA Chemical Inventory Fred Arnold, EPA Economics, Exposure and Technology Division, Office of Pollution Prevention and Toxics, Aaron Osborne, ERG, slide 16 (undated) [hereinafter Slide Instructions]. 

Inventory it is now possible to determine if the chemical in question is produced for commercial purposes and the level of its production. The TSCA Inventory, however, is only a one-time information collection effort by EPA. It does not provide historical production information, and its update depends on the Premanufacture Notification (PMN) and the Significant New Use Regulations (SNUR), which are under development by EPA. The PMN regulation will provide for addition of new compounds to the inventory. The form of the SNUR regulation is not yet clear, but we can expect that manufacturers will be required to report significant new uses for chemicals already listed on the inventory, along with production figures. 

Section 8 of TSCA authorizes the EPA to require the reporting and record keeping of information involving chemical use and exposure. This includes an update of the chemical inventory undertaken by a mandatory survey form for all manufacturers, processors and importers every four years. Section 8(c) of TSCA involves reports of allegations of significant adverse reactions. Section 8(d) of TSCA requires the collection of unpublished health and safety studies on specified chemicals. Section 8(e) of TSCA requires the reporting of information that a substance presents a substantial risk of injury to health or the environment. 

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