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Insights on the EPA’s TSCA 2012 CDR Requirements

Posted by Shivi Kakar

Nov 21, 2011 3:25:11 PM

TSCA 2012 CDR SubmissionPaula Kaufmann, CIH

The EPA hosted a 3-hour webinar on November 16, 2011 that reviewed the reporting process for the 2012 Chemical Data Reporting (CDR) Rule with a focus on joint reporting, considerations related to the reporting of byproducts, and updated information about registering for electronic reporting and for using the electronic reporting tool/  The EPA has posted the presentation slides online and expects to have a recording of the webinar available for viewing by December 1.

Webinar Take Aways – Still Many Questions

  • The Agency has prepared a detailed instruction manual for the 2012 CDR that presents the reporting requirements using a decision logic diagram.

  • Registration for the EPA Central Data Exchange (CDX) for CDR submission is scheduled to be opened on December 1.  The sign-up link will be posted on the IUR/CDR Home Page. (Emilcott will also post it on our TSCA Resource Web Page.)

  • e-CDR web, the CDR reporting tool, is scheduled to be available in January.

  • The TSCA Substance Registry Services (SRS) will be updated in January.

  • Additional resources will continue to be posted at

  • A few of the new requirements highlighted during the presentation brought in many questions during the subsequent 2-hour webinar Q&A – specifically concerning Contract Manufacturing, Joint Submission, and byproducts reporting.

Some of the questions not answered during the webinar that we found of particular interest are:

  • What are the reporting responsibilities for toll manufacturers where the volume of a chemical made for one customer is less than 25,000 lbs but they manufacture for several customers putting the cumulative volume above the threshold?

  • What does one do since the XML Schema that is currently posted does not function properly, and is stated to be the final version?

  • Does starting material that is recycled (and reused) need to be reported since the material was not manufactured at the site?

  • If off-specification material is reprocessed, does the material gained from the reprocessing get reported as a byproduct or is it included in the overall production volume?

  • How does one account for non-isolated intermediates that are isolated and then reprocessed due to maintenance activities or upset conditions?

  • What are the reporting responsibilities for an importer if the supplier does not agree to be a joint submitter?

As the reporting period nears we will be taking a careful look at the rationales and explanations provided in the Preamble to the Final Rule as the buck stops with the final rule as published.

If you need guidance for the EPA TSCA 2012 CDR Submission, Emilcott offers three helpful options

  1. Contact Emilcott  directly with your questions about TSCA or other regulatory issues.

  2. Subscribe to our free TSCA newsletter which delivers TSCA-related information just like this right to your mailbox.

  3. Register for our free Dec 6 webinar:  Do You Understand TSCA 2012 CDR Requirements?

Topics: EPA, TSCA & R.E.A.C.H., TSCA, CDR, 2012, submission, Preamble, Webinar, final rule, November 16

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