Reporting and Recordkeeping

While a company is evaluating whether a polymer quaUfies for the polymer exemption, the company must follow the rules for the R D exemption from premanufacure notice requirements if it has not filed a PMN and an NOG 

Once a company has done enough research to conclude that a polymer it manufactures falls within the polymer exemption, it must follow the recordkeeping and reporting requirements set out in the polymer exemption.  

The reporting requirements in the polymer exemption require each manufacturer and importer to mail a report to the EPA by January 31 of each year providing information on each polymer that it has manufactured or imported for the first time during the previous calendar year. A company may submit a report for each plant site or one consolidated report for the entire company, but should not duplicate information if it submits one report for each plant site. The report must include the following information  

The EPA uses these letters to determine what plants to audit for compliance with the polymer exemption, and to track how often companies rely on the polymer exemption. 

If the exempt polymer also meets the requirements of the R D exemption, then a manufacturer or importer can rely on the R D exemption and not file the annual notifications that would otherwise be due.  

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Industrial Pollutant Monitoring for recordkeeping and report generation and Process Monitoring/Rcporting for process reports and other reports. Each requires 512K memory and lOMeg hard disk. 

The only regulations found for organophosphate ester hydraulic fluids were for aryl phosphates. Two proposed rules for aryl phosphates address 1) exclusion from hazardous waste regulations and 2) additional testing, recordkeeping, and reporting under the Toxic Substances Control Act (TSCA). 

Section 8 - enables the EPA to require recordkeeping and reporting of information. Part of this authority includes the direction for the Agency to compile an inventory of all chemical substances in commerce. The basic information gathering activities are Section 8(a) - reporting of production, use,... 

In broad terms, the regulations require operations, products, or activities which conform to the regulation. They also may demand monitoring, recordkeeping, and reporting to document compliance. 

Advise all distributors of these List I chemicals that it is unlawful for any person to possess or distribute a listed chemical knowing, or having reasonable cause to believe, that the listed chemical will be used to manufacture a controlled substance in violation of the Controlled Substances Act...21 U.S.C. 841(c)(2). Persons who violate 21 U.S.C. 841(c)(2) and/or the recordkeeping and reporting requirements are subject to criminal and/or civil penalties. Source DEA 05/01/03... 

Allegations of Significant Adverse Reactions Recordkeeping and Reporting Rule... 

This book provides an easy-to-read guide to tire subject of RCRA and waste management The book details lmf>ortant Information such as how to identify a hazardous waste, how to classify the waste, recordkeeping and reporting requirements, transportation requirements, and other aspects of hazardous waste management... 

Notably, the Universal Waste Rule did not reduce regulatory burdens on Ni-Cd recycling facilities. They continue to be required to have hazardous waste facility permits, facility closure plans and demonstrations of financial responsibility, employee training, storage requirements, and recordkeeping and reporting obligations. This is appropriate, as these facilities open the batteries and crush the constituents. Such activity, if done improperly, could represent a threat to human health and the environment. 

They also require maintaining records of allegations of significant adverse effects. The major recordkeeping and reporting requirements in TSCA 8 are ... 

Questions and Answers Concerning the TSCA Section 8(c) Rule, Questions Received at Seminar on Toxic Substances Control Act Section 8(c) Recordkeeping and Reporting Allegations of Adverse Reactions November 10,1983 (July 1984) 8c QA 7-84... 

The regulations of the Administrator under this subchapter shall include such recordkeeping and reporting requirements as may be necessary to insure the... 

The TSCA inventory (a list of 70,000 toxic chemicals) was established to record all products manufactured, imported, sold, processed, or used for commercial purposes. Exemptions include R D chemicals and by-products without commercial purpose. The TSCA also controls premanufacture review of new chemical substances, risk assessment by testing and information gathering, recordkeeping and reporting on health and environmental effects associated with chemical substances, and restrictions on known hazardous chemicals. 

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