Products to Controlled Chemical Substances

The irutial task is to imderstand the natme of what the company sells and how it enters a new product into its internal business system. Does the company sell articles If so, it wiK first need to determine if the article contains a chemical substance or mixture which has a separate end use from the article and will be released or removed from the article. If it does not contain such substances or mixtures, the article is not subject to TSCA 12(b), except if it contains PCBs in a concentration of more than fifty parts per milUon or except if it contains substances that are specifically restricted in articles in 5, 

The next step is to have a mechanism for checking the chemical substances in the master repository against the fist of chemicals subject to 12(b). 

As noted above, there are a variety of sources of such Ksts, such as the one 

59 Fed. Reg. 11122, 11142 (Mar. 9, 1994). Hiis proposed ban on small lead and zinc sinkers explicitly requires export notifications. See EPAs Current List of Chemical Substances Subject to TSCA Section 12(b) Export Notification Requirements (Oct 10,2009), availabk at http //www.epa.gov/oppt/import-export/pubs/12blistpdf. EPA has indicated it is re-evaluating this proposed rule. Fall 2009 Regulatory Agenda, 104. 

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