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The 2012 TSCA CDR Submission Period Begins! Rev up your calculators and keyboards, NOW!!

Posted by Shivi Kakar

Feb 9, 2012 6:18:57 AM

By Paula Kaufmann, CIH

The news is good!  With the submission period starting on February 1, 2012 - the eCDR tool is up and running … allow time for the CDX registration (you’ll need an authorized official and a primary support person set up for your company).   You can set up your sites NOW, and you’ll be all ready to start entering data whenever you desire!

At Emilcott, we’ve set up a couple of nifty (well, we think they are) spreadsheets to allow us to gather industrial processing/use and consumer and commercial use for Section 3 of the 2012 Form U.  These Excel spreadsheets can stand alone (don’t need to be accessed online).  We’ve designed the spreadsheets to match the terminology and options coded into eCDR – so that it is a snap to transfer the information directly to the eCDR.  We’ve got a demo set up – just click on the image below:

The EPA has posted quite a bit of new information about CDR reporting and the eCDR submission system – some the information is new with some clarification of issues responding to the multitude of questions coming in from potential Form U submitters. Even with all this information, it is a complex path – if you have any questions, please give me call at 973-538-1100 or drop me at note at - at Emilcott we are fielding many questions from our clients, and just may have the information you need!  Here’s the new information up on the EPA’s website -

There is an entire section of the EPA’s “Pollution Prevention and Toxics Frequent Question Knowledge Base” dedicated to the CDR.  This information is presented in a couple of different formats … check it out by clicking below or at this link  “Answers to your questions about Chemical Data Reporting”

The “Instructions for the 2012 TSCA Chemical Data Reporting” (January 2012) has been revised.  Be sure to review this new guide as there have been some major changes in the document including an entirely new chapter on the CDX and eCDRweb.  The revision provides more detailed information about Joint Submissions … and with additional information about several more subtle issues.

The EPA has provided some additional byproducts and recycling scenarios which give us additional information on the 2012 CDR in the January 20, 2012 document  “2012 Chemical Data Reporting: Byproduct and Recycling Scenarios”. In addition, in the updated “Instructions” the EPA adds new example of based on spent solvents.  There is more information on recycling and when reporting is required as well.

Since the electronic submission system does require multiple steps and, a few leaps, the EPA has posted several documents to “guide the way”.  I still needed to call the eCDR hotline to get a few issues cleared up … and it can take 2-3 weeks for the EPA to process a “mailed in” signature of the Authorized Official.  Consider getting set up NOW on the CDX registration and the eCDR link (which is the CSPP registration) even if you are not prepared to begin to complete the Form U.

CSPP CDX Registration Guide– How to register for CDX and access the e-CDRweb reporting tool

E-CDRweb User Guides – How to use the CDR electronic reporting tool

All the EPA CDR training modules have been posted.  There are 7 modules with topics covering an overview of the IUR modifications and Chemical Data Reporting Final Rule; 2012 CDR reporting requirements with modules focused on joint submission and byproducts; and, of course, Form U completion and electronic reporting.

Have you been able to get through the CDX registration process, set up your reporting facilities, and accessed the eCDR for your sites?  Please let us know your take aways and lessons learned … let’s share your wisdom!

Topics: Emilcott, TSCA & R.E.A.C.H., TSCA, CDX registration, CDR, Toxic Substance Control Act

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