If you are a foreign or domestic business in the US who is either a chemical importer (resells for use in blending, repackaging) or chemical manufacturer (make new chemicals out of chemicals purchased from others with the exception for pharmaceutical companies), this update is about mandatory compliance with the EPAs Toxic Substances Control Act (TSCA), specifically filing the 2012 TSCA Form U Chemical Data Report.
Emilcott recently participated in an industry preview (the unveiling!) of the e-CDRweb tool. Based on this peek, we are optimistic that the tool will be functional and surmountable IF all the required information is gathered together prior to preparing the submission. As a test run, we entered simulated data and found the online tool to be logical and the built-in validation system should assist submitters with identifying inconsistent or incomplete entries.
Our conclusion: The difficulty will most likely not be the use of the e-CDRweb tool, the greater challenge will be the effort and time required to gather the right data needed for the submission.
Our advice: START GATHERING THE REQUIRED DATA NOW!!
Start with the following 2010 and 2011 inventory and volume data:
- Review the Form U data needed, consider the time you will need to obtain these data, and then allow additional time for getting follow-up, incomplete or missing information.
- Determine Co-Submitters for chemicals that are toll manufactured.
- Get the CAS number for all chemicals at or above the 25,000 lb threshold. Prescient warning: the need to submit a CAS number or accession number for each chemical may require significant effort and time for submitters with suppliers that list confidential for the component.
- Define which suppliers will need to be joint submitters.
- Discuss and agree upon this with the supplier.
Get the CDX registration and authorizations completed a multi-step, multi-party and possibly lengthy process.
- CDX registration for e-CDRweb will be available on November 1, 2011.
- Primary Authorized Official must be registered first as this activates the account.
- Designate the Primary Support
- Establish the Secondary Authorized Officials (joint submitters) by chemical substance
In summary, if you were to compare filing the EPAs TSCA submission to the IRSs income tax form, the e-CDRweb tool is definitely going to be easier. However, understanding what to get and where to get it and then digging up the required information for the TSCA submission is going to be challenge.
If you need guidance with what data you should for the EPA TSCA 2012 CDR Submission, please contact Emilcott!
You can also subscribe to our free TSCA e-newsletter which delivers information right to your mailbox. Want more info? Enroll for our free Dec webinar by sending an email to firstname.lastname@example.org.
Feel free to post any questions below in the comments section and we will respond quickly.