Search

TSCA Chemical Data Reporting: The New Form U and You

Posted on 1/10/2012 by James Griffin

On August 16, 2011 (76 FR 50816), EPA published its new Chemical Data Reporting (CDR) Rule, replacing the previously existing Inventory Update Report (IUR) Rule. While the form for submitting data remains the same (the Form U), some key information has changed.
 
History
In 1978, EPA compiled what is now known as the TSCA Master Inventory. In addition to mechanisms for adding new chemicals to the inventory (a subject for another time), EPA also requires manufacturers and importers to periodically submit specific information about substances on the inventory, including recent publications and site data, to better track the presence of these chemicals in the marketplace.
 
Between 1978 and 2006, EPA amended the Inventory Update Rule a number of times. In 2011, EPA considered making some major changes. The result was a delay in the announced reporting due date. Originally, data on 2010 production was due in mid-2011, but EPA told sites subject to the IUR to hold off on data submission until the new rule was finalized.
 
What’s the difference between the IUR and the CDR?
 The August 16, 2011 rule did more than just change the name of the reporting requirement. It also changed:
 
  • The location of the regulations. The IUR rules were in 40 CFR 710. The CDR rules are in 40 CFR 711.
  • The frequency of reporting. The IUR was on a five-year cycle. The CDR is a 4-year cycle. The current report is due in 2012 and the next reporting year will be 2016.
  • The submission period. Instead of the usual June 1 through September 30 period, the report is due between February 1 and June 30, 2012. (The June—September period will be reinstated for the 2016 report.)
Who is subject to CDR?
“For the 2012 submission period, any person who manufactured (including imported) for commercial purposes 25,000 lbs. (11,430 kg) or more of a chemical substance [on the inventory] at any single site owned or controlled by that person during the principal reporting year (i.e., calendar year 2011) is subject to reporting.” [40 CFR 711.8(a)]
 
Will there be more changes?
In addition to returning the submission period to June through September for the 2016 reporting year, there will be other changes. For 2016, any person who manufactured 25,000 lbs. or more of a chemical substance on the Inventory in ANY calendar year since the previous reporting year will have to submit the Form U in 2016.

Tags: EPA, reporting and recordkeeping, TSCA

Find a Post

Compliance Archives

Lion - Quotes

Very witty instructor, made the long times sitting bearable. One of the few training courses I can say I actually enjoyed.

John Hutchinson

Senior EHS Engineer

The instructor was very knowledgeable and provided pertinent information above and beyond the questions that were asked.

Johnny Barton

Logistics Coordinator

I have over 26 years of environmental compliance experience, and it has been some time since I have attended an environmental regulations workshop. I attended this course as preparation for EHS Audits for my six plants, and it was exactly what I was looking for.

Frank Sizemore

Director of Regulatory Affairs

Much better than my previous class with another company. The Lion instructor made sense, kept me awake and made me laugh!

Marti Severs

Enterprise Safety Manager

I can take what I learned in this workshop and apply it to everyday work and relate it to my activities.

Shane Hersh

Materials Handler

The instructor took a rather drab set of topics and brought them to life with realistic real-life examples.

Tom Berndt

HSE Coordinator

I used the IT support number available and my issue was resolved within a few minutes. I don't see anything that could have made it better.

Danny Province

EHS Professional

The instructor clearly enjoys his job and transmits that enthusiasm. He made a dry subject very interesting and fun.

Teresa Arellanes

EHS Manager

Lion's course was superior to others I have taken in the past. Very clear in the presentation and the examples helped to explain the content presented.

George Bersik

Hazardous Waste Professional

Given the choice, I would do all coursework this way. In-person courses go very fast without the opportunity to pause or repeat anything.

Ellen Pelton

Chemical Laboratory Manager

Download Our Latest Whitepaper

Hazardous materials shipment rejections bear a big cost. Use this guide to end operational and logistical disruptions that severely impact your bottom line.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.