In 2016, certain companies will be required to submit exposure-related information on the types, quantities, and uses of chemical substances manufactured domestically and imported into the United States. In a recent webinar, titled New Chemical Data Reporting Requirements under TSCA: What to Do Right Now to Prepare for 2016 Filings, speaker Pam Dickerson, CHMM, of Cornerstone Environmental, Health and Safety Inc., discussed who is impacted and what they must do to comply with chemical data reporting requirements under the Toxic Substance Control Act (TSCA).

Chemical Data Reports (CDRs) must be submitted every 4 years. Companies manufacturing or importing a chemical in the TSCA Inventory above certain thresholds at a single site are required to submit a CDR. Dickerson detailed the applicability thresholds and potential exemptions, including highlighting how the applicability thresholds have changed since the last CDR was due in 2012. Some key points mentioned in relation to applicability thresholds included:

• Reporting is not limited to large manufacturers, as the threshold for certain chemicals subject to specific TSCA actions is now set at 2,500 pounds per year;
• For the 2016 CDR, if the applicability threshold is exceeded in any year, reporting must be done for all years; and
• Mixtures need not be considered, but the individual components of the mixture must be evaluated.

The webinar went on to cover the collection of data required for a CDR submission, and Dickerson clearly differentiated which data are required for all of the reporting years (i.e., 2012, 2013, 2014, and 2015) and which data must only be submitted for the principal reporting year (i.e., 2015).

While the regulations specify recordkeeping requirements for reported chemicals, Dickerson recommended also keeping records to document any reasons why a chemical may not be reported.

The webinar concluded by covering the complex topics of confidential business information and joint CDR submissions, which may be required if a supplier will not disclose a specific chemical name to a manufacturer or importer. In addition, Dickerson touched on the CDR submission process, which must be done using EPA’s e-CDR online reporting tool.

The CDR submission period begins June 1 and ends September 30, 2016, but it is not too early to start gathering your data and determining applicability. So, get started!