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TSCA Inventory Notification (Active/Inactive) Requirements

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The Fertilizer Institute filings
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The Fertilizer Institute filed 1 comment on this docket between Mar 15, 2017 and Mar 15, 2017. 36 other organizations filed here. The comment window closed 3423d ago.

What The Fertilizer Institute filed (1)

Mar 15, 2017· Comment submitted by Ed Thomas, Director, Regulatory Affairs, The Fertilizer Institute (TFI)· EPA-HQ-OPPT-2016-0426-0028

The Fertilizer Institute (TFI), on behalf of its member companies, submits these comments on the U.S. Environmental Protection Agency's (EPA or Agency) proposal "TSCA Inventory Notification (Active-Inactive) Requirements" (hereinafter "Proposed TSCA Inventory Reset Rule"). The Proposed TSCA Inventory Reset Rule was published in the Federal Register on January 13, 2017 and appears at 82 Fed. Reg. 4,255. Statement of Interest TFI represents the nation's fertilizer industry including producers, importers, retailers, wholesalers and companies that provide services to the fertilizer industry. TFI members provide nutrients that nourish the nation's crops, helping to ensure a stable and reliable food supply. TFI's full-time staff, based in Washington, D.C., serves its members through legislative, educational, technical, economic information and public communication programs. All of TFI's manufacturing members are subject to the Proposed TSCA Inventory Reset Rule and will be subject to the rules provisions. TFI offers the following comments on the Proposed TSCA Inventory Reset Rule: TFI Executive Summary The TSCA inventory reset will impact companies in several ways. TFI's primary concerns are summarized below: The agency should not require reporting of information unnecessary to achieve the overall purpose of the inventory reset, which is to identify substances as either active or inactive. Any acquisitions or divestitures that are in process or have taken place historically may impact the ability of a company or a successor in interest to assure all business critical substances are added to the active inventory. In the absence of guidance, the current proposed rule could lead to potential business interruption. Resources will be needed to gather, review and submit the data required by the initial submittal. The resources needed will be similar to those required for Chemical Data Reporting (CDR). The level of resources needed will be dependent on whether EPA makes changes to the data requirements as indicated in our position. While companies will approach the preparation of reports with the highest level of due diligence, a mechanism is needed to make corrections in case substances are missed or reported incorrectly. Substances that fall below the CDR reporting threshold and are not routinely tracked and therefore may have less documentation and may require more diligence are the areas of greatest risk for error. The agency must provide guidance for mergers, acquisitions, and divestitures. The agency must allow for a correction process for manufacturers and importers up until the time that the active inventory is finalized.

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Abstract

TSCA Inventory Reporting Rule for reporting Chemical Substances that are active in commerce, as promulgated by the Frank R. Lautenberg Chemical Safety for the 21st Century Act (“TSCA 21”) [sections 8(b)(4)(A) & 8(b)(5)(B)(i)]. The Act requires manufacturers to notify the Administrator of each chemical substance on the Inventory that was manufactured or processed in the United Sates for a nonexempt commercial purpose during the 10-year period ending on June 21, 2016, the day before the date of enactment of TSCA 21. The Administrator shall designate chemical substances for which notices are received to be active, and those for which no notice is received to be inactive. Manufacturers that intend to commercialize inactive chemicals in the future must notify the Administrator in order for those chemicals to be changed to active status.

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Co-filers (36)

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