Nonconforming commercial product

Procedure Number CORP. 19, Control of Nonconforming Commercial Product Procedure Nonconf Product... 

As discussed in The Inventory Chapter, 5 of the Toxic Substances Control Act (TSCA) requires that all chemicals manufactured, processed, or used in the United States must be on a comprehensive list of chemicals maintained by the United States Environmental Protection Agency pursuant to 8(b) of TSCA, called the TSCA Inventory. When commercial product is not manufactured according to specifications, that nonconforming product could be, or could contain, a chemical substance not on the TSCA Inventory, which would limit the ability to sell the product as is or to rework it. This procedure deals with how to assess the TSCA implications of the management of manufactured nonconforming commercial product. 

This procedure describes the method for controlUng the disposition of manufactured nonconforming commercial product. 

Step 1. The management of nonconforming commercial product is considered by a business team assigned to that product. Indicate which functions in... 

Step 5. The MRC must evaluate each completed and prospective action to determine whether a new chemical substance required to be on the TSCA Inventory was formed during the manufacture of the nonconforming commercial product, is in the nonconforming commercial product, or will result from the reworking of the nonconforming commercial product. The MRC must also evaluate whether a chemical substance subject to a Significant New Use Rule (SNUR) or any other restriction is a component of the nonconforming product The Liaison must provide the MRC with information needed to complete such evaluation. 

It is highly unhkely that a company will want to take the time and trouble to put a substance on the Inventory to be able to dispose of nonconforming commercial product in a way otlier than waste, but we leave this option here for consideration in the event that the product was produced in very large quantities or was very expensive. 

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