Toxic Substance Control Act -Best Practices and Future Reform Update

摘要

In July of 2012, refineries, along with other manufacturers, were required to submit chemical production information under the Toxic Substance Control Act's (TSCA) Chemical Data Reporting Rule (CDR). The CDR is the most comprehensive set of information on chemical substances and their proposed uses available to EPA and the public. While supporting several facilities with the CDR, Trihydro Corporation (Trihydro) faced several challenges during the 2012 submission period related to regulatory changes from the previous submission year and general reporting complications. Resolving the issues led Trihydro to develop best practices and recommendations to reduce the CDR burden for future reports. Since the CDR required reporting is every four years, Trihydro also recommends several practices that facilities should be doing in the meantime. Many of Trihydro's recommendations are based on knowledge of the 2012 reporting period and the current regulation, TSCA reform is underway in Congress. While much of the reform is proposed, facilities should be aware of potential changes to the regulation.