ILMA Compoundings October 2017 - 48

WASHINGTON LANDSCAPE

EPA Publishes Final TSCA
Inventory Reset Rule
By Daniel Bryant

T

he Toxic Substances Control
Act (TSCA) was significantly
amended in June 2016 by the
Frank R. Lautenberg Chemical Safety
for the 21st Century Act (LCSA). The
amendments mandated, in part, that
the Environmental Protection Agency
(EPA) issue a final rule by June 22,
2017, to determine what chemicals are
"active" and "inactive" in commerce.
The regulation is commonly referred
to as the "inventory reset rule."
The final regulation was announced
in June and was published in the Federal Register on Aug. 11, 2017. The
formal publication date is significant,
as it commences the "compliance
clock" for affected entities to submit
their TSCA inventory notifications
to the EPA. ILMA members should
review the rule carefully to ensure
there are no supply interruptions or
disruptions in their abilities to use
certain chemical substances.
RETROSPECTIVE REPORTING
Under the final inventory reset rule,
retrospective reporting applies to
manufacturers and importers of
chemicals that were manufactured or
imported for nonexempt commercial
purposes during the 10-year period
from June 21, 2006, through June
21, 2016. The EPA did reduce the
volume of information that manufacturers and importers are required to
provide in the final rule, eliminating
the requirements that a date range of
manufacture and the type of activity
(e.g., if manufactured or imported)
be provided. Now entities must only

48

OCTOBER 2017

| COMPOUNDINGS | ILMA.ORG

verify that the chemical was produced
at some point during the "look-back"
period, which should reduce compliance burdens somewhat as confirmation of precise date ranges would likely
have proved time-consuming.
Manufacturers and importers have
until Feb. 7, 2018, to submit notifications to the EPA using the agency's
Central Data Exchange (CDX) reporting portal. Once the manufacturers'
and importers' information is reviewed
and compiled, the EPA will publish a
"draft reset inventory" that will outline
all of the information received.
Processors, including some ILMA
manufacturing members, should
review the draft inventory closely to
ensure that all substances relevant for
their operations were reported to the
agency. Processors have until Sept. 5,
2018, to report substances voluntarily
to the EPA.
EPA officials intend to generate
the draft inventory within 60 days of
receipt of manufacturer-provided data,
meaning that it should be published
around mid-April next year. The agency

already has listed 9,627 chemicals
it presumes are in commerce on an
interim list of active substances.
REPORTING EXEMPTIONS
Importantly, the EPA created three
categories of excluded substances in
the final rule. First, manufacturers and
importers will not need to resubmit
information on chemicals reported
under the Chemical Data Reporting
program in 2012 and 2016. Second,
substances on the TSCA inventory
based on pre-manufacture notification
(PMN) submissions do not need to
be re-reported to the agency. Third, a
manufacturer is exempt from the retrospective notification requirements for a
chemical substance if the manufacturer
has a CDX receipt that the EPA received a notification (Notice of Activity
Form A) from another manufacturer.
FORWARD-LOOKING REPORTING
AND THE TRANSITIONAL PERIOD
In addition to retrospective reporting requirements, the final rule also mandates
that manufacturers and processors notify
the EPA of their intent to manufacture


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ILMA Compoundings October 2017

Table of Contents for the Digital Edition of ILMA Compoundings October 2017

LETTER FROM THE CEO
LETTER FROM THE PRESIDENT
INSIDE ILMA
WHAT’S COMING UP
INDUSTRY RUNDOWN
In the Know
International Insight
Market Report
BUYING OR SELLING
INCREASED LITHIUM DEMAND, SHORTAGES LEAD TO PRICE SPIKES FOR GREASE MANUFACTURERS…
MANAGING INVENTORY: WHAT’S IN YOUR TOOL CHEST?
BUSINESS HUB
COUNSEL COMPOUND
WASHINGTON LANDSCAPE
IN NETWORK
Company Callout
Member Connections
Cross Connections
PORTRAIT
ILMA Compoundings October 2017 - Cover1
ILMA Compoundings October 2017 - Cover2
ILMA Compoundings October 2017 - 1
ILMA Compoundings October 2017 - 2
ILMA Compoundings October 2017 - LETTER FROM THE CEO
ILMA Compoundings October 2017 - 4
ILMA Compoundings October 2017 - LETTER FROM THE PRESIDENT
ILMA Compoundings October 2017 - INSIDE ILMA
ILMA Compoundings October 2017 - 7
ILMA Compoundings October 2017 - 8
ILMA Compoundings October 2017 - 9
ILMA Compoundings October 2017 - WHAT’S COMING UP
ILMA Compoundings October 2017 - 11
ILMA Compoundings October 2017 - INDUSTRY RUNDOWN
ILMA Compoundings October 2017 - 13
ILMA Compoundings October 2017 - 14
ILMA Compoundings October 2017 - In the Know
ILMA Compoundings October 2017 - International Insight
ILMA Compoundings October 2017 - 17
ILMA Compoundings October 2017 - 18
ILMA Compoundings October 2017 - 19
ILMA Compoundings October 2017 - Market Report
ILMA Compoundings October 2017 - 21
ILMA Compoundings October 2017 - 22
ILMA Compoundings October 2017 - 23
ILMA Compoundings October 2017 - BUYING OR SELLING
ILMA Compoundings October 2017 - 25
ILMA Compoundings October 2017 - 26
ILMA Compoundings October 2017 - 27
ILMA Compoundings October 2017 - 28
ILMA Compoundings October 2017 - 29
ILMA Compoundings October 2017 - INCREASED LITHIUM DEMAND, SHORTAGES LEAD TO PRICE SPIKES FOR GREASE MANUFACTURERS…
ILMA Compoundings October 2017 - 31
ILMA Compoundings October 2017 - 32
ILMA Compoundings October 2017 - 33
ILMA Compoundings October 2017 - 34
ILMA Compoundings October 2017 - 35
ILMA Compoundings October 2017 - MANAGING INVENTORY: WHAT’S IN YOUR TOOL CHEST?
ILMA Compoundings October 2017 - 37
ILMA Compoundings October 2017 - 38
ILMA Compoundings October 2017 - 39
ILMA Compoundings October 2017 - 40
ILMA Compoundings October 2017 - 41
ILMA Compoundings October 2017 - BUSINESS HUB
ILMA Compoundings October 2017 - 43
ILMA Compoundings October 2017 - 44
ILMA Compoundings October 2017 - 45
ILMA Compoundings October 2017 - COUNSEL COMPOUND
ILMA Compoundings October 2017 - 47
ILMA Compoundings October 2017 - WASHINGTON LANDSCAPE
ILMA Compoundings October 2017 - 49
ILMA Compoundings October 2017 - Company Callout
ILMA Compoundings October 2017 - 51
ILMA Compoundings October 2017 - Member Connections
ILMA Compoundings October 2017 - 53
ILMA Compoundings October 2017 - Cross Connections
ILMA Compoundings October 2017 - 55
ILMA Compoundings October 2017 - 56
ILMA Compoundings October 2017 - 57
ILMA Compoundings October 2017 - 58
ILMA Compoundings October 2017 - 59
ILMA Compoundings October 2017 - PORTRAIT
ILMA Compoundings October 2017 - Cover3
ILMA Compoundings October 2017 - Cover4
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