Greenwich Chemical Consulting, Inc. Blog

Greenwich Chemical Consulting is the leading provider of TSCA and chemical consulting services. Greenwich Chemical Consulting, Inc. 3300 PGA Blvd, Suite 635 Palm Beach Gardens, FL 33410 561.578.8110 www.grcci.com

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Ready to meet the EPA's new 2011 TSCA IUR Rule?

John V. Massingale

President, Greenwich Chemical Consulting, Inc.

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2011 TSCA IUR Rule Highlight #5: Broader, more rigorous reporting standard

The EPA is proposing to replace the "readily obtainable" reporting standard currently used for the reporting of processing and use information with the broader and more rigorous "known to or reasonably ascertained by" reporting standard.

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2011 TSCA IUR Rule Highlight #4: Inorganic chemicals partial exemption no longer applicable

Under the proposed rule, the partial exemption for inorganic chemicals will no longer be applicable and submitters will report in the same manner as for organic chemicals including processing and use information. (For the 2006 submisison only, inorganic chemical substances were partially exempted from the IUR rule, and manufacturers of such chemicals were required to report the manufacturing information and not the processing and use information regardless of production volume.)

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2011 TSCA IUR Rule Highlight #3: ECA ineligible for exemptions

The EPA is proposing to amend the IUR regulations to make chemical substances, on which an enforceable consent agreement (ECA) to conduct testing exists, ineligible for exemptions.

In addition, the amendments provide a full exemption from IUR requirements for water and remove polymers that are already fully exempt from the partially exempt list of chemical substances.

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2011 TSCA IUR Rule Highlight #2: Eliminated 300,000 lb. threshold

The EPA is proposing to amend the IUR regulations to eliminate the 300,000 lb. threshold for processing and use information thereby requiring all reporters of non-excluded chemical substances to report information in all parts of the Form U.

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Published memo on proposed TSCA IUR Rule for 2011.

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2011 TSCA IUR Rule Highlight #1: Electronic-only reporting

The EPA is proposing to amend the IUR regulations to require electronic reporting of the IUR data using EPA-provided, web-based reporting software (e-IURweb) to submit IUR reports through the internet to the Agency's Central Data Exchange (CDX). Paper submissions would no longer be accepted.

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EPA's 2011 TSCA IUR Rule to be announced this Spring

Did you know that the proposed 2011 TSCA IUR Rule significantly expands the scope of the IUR reporting requirements from those in the 2006 IUR?

The IUR regulation requires manufacturers and importers of certain chemical substances included on the TSCA Chemical Substance Inventory to report site and manufacturing information for chemicals manufactured (including imported) in amounts of 25,000 pounds or greater at a single site. Additional information on domestic processing and use must be reported for chemicals manufactured in amounts of 300,000 pounds or more at a single site. EPA uses the IUR data to support many health, safety, and environmental protection activities. http://www.epa.gov/oppt/iur/