First Call: TSCA Inventory Update – June 1 to Sept 2011

Craig A. Calvert, Ph.D., C-CHO
August 2, 2010
Welcome to the August issue of the Industrial Safety Newsletter. As the current year starts passing us by and we start planning for next year, one important report is due – the TSCA Inventory (Form U submissions). In short if you…“manufacture (including import) 25,000 pounds or more of a chemical substance at a single site during calendar year 2010, you may need to report under the Inventory Update Reporting (IUR) regulation 40 CFR Part 710 subpart C” (USEPA). Please note that there are exceptions, so consult a TSCA expert to determine your exact requirements. This issue of the safety newsletter will review the reporting process. We hope that you find this newsletter useful and look forward to providing you with the quality service and information that has made Fuss & O'Neill EnviroScience successful.
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Ÿ TSCA was enacted to prevent particularly toxic chemicals from being produced*
Ÿ Part of TSCA is the TSCA Chemical Substance Inventory, which tracks chemicals produced in the US.
§ The information is gathered to monitor the chemicals produced in the US
Ÿ The definition of a chemical substance is:
“any organic or inorganic substance of a particular molecular identity, including: (i) any combination of such substances occurring in whole or in part as a result of a chemical reaction or occurring in nature, and (ii) any element or uncombined radical.” (EPA) Note: This includes certain microorganisms and there are exceptions.
Ÿ Generation of the 2011 Report is based on 2010 manufacturing quantities
§ The next IUR submission period is currently planned for June 1 - September 30, 2011
§ Changes are expected from the 2006 reporting procedure
§ Note to inorganic chemical manufacturers:
Inorganic chemicals are no longer partially exempt from the IUR rule
The partial exemption was a one-time exemption for 2006 reporting only
Ÿ A summary of the data from the 2006 inventory is available in an EPA report*
Ÿ EPA is working on a number of changes for 2011 reporting
§ Making the electronic reporting easier and more accessible to all potential reporters
§ Redesigning the electronic IUR reporting software
§ EPA is deliberating on changes to the specific reporting requirements
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Fuss & O'Neill is a multi-disciplined industrial hygiene and environmental engineering firm that has provided a wide variety of regulatory reporting services. Our experts will work with your facility to ensure safe, timely, and legal submission of your Form U. In this process we will lead you through the process or take the lead for you. The goal of our service is to provide timely and correct submission of your TSCA regulated chemicals.
*For more information and for copies of the referenced documents contact:
Craig A. Calvert, Ph.D., C-CHO
ccalvert@fando.com
(860) 646-2469 x5571

For more information on TSCA visit: www.tscaconsulting.blogspot.com/

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