Bergeson & Campbell, P.C.

Big Changes Ahead in IUR Reporting

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Courtesy of Courtesy of Bergeson & Campbell, P.C.

On Jan. 7, 2003, the U.S. Environmental Protection Agency (EPA) issued its long-awaited amendments to the Toxic Substances Control Act (TSCA) Section 8(a) Inventory Update Rule (IUR). The news is mixed. On the bad news side, completing IUR Form U will be significantly more complicated in the next IUR reporting period. Certain exposure-related information will be required for chemical substances covered by the IUR, and inorganic chemical substances now are subject to IUR reporting because EPA decided to revoke the full exemption from IUR reporting for these substances.

On the good news side, however, EPA raised production-volume basic reporting thresholds for chemical substances, as well as the thresholds for reporting of processing and use information.

Entities that historically have prepared IUR Form U will notice many other changes of significance. Similarly, new submitters that now must report because of the rule’s expanded scope — including inorganic chemical substances, among other changes — will be challenged by the new reporting obligations.

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