Chemical Testing Under TSCA -- Who Is On the Hook (PDF)

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Manufacturers of chemical products and products that contain significant chemical components need to be aware of subtle but important changes in the “persons required to test” provisions of Section 4 of the Toxic Substances Control Act (TSCA).  Historically, those persons have included chemical manufacturers, processors, or those who intend to process or manufacture a Section 4 test rule substance. In the recent past, the United States Environmental Protection Agency (EPA) has sought to expand the class of persons required to test to include persons whose actions result in the release of the test rule substance into the environment, thus enhancing opportunities for chemical exposure.  EPA’s evolving policy has potentially enormous implications for a diverse range of business entities.  The significance of these changes should not be overlooked. Many more businesses could be required to bear the cost of potentially significant TSCA Section 4 testing requirements. This article discusses EPA’s historic Section 4 test standard, reviews EPA’s more recent interpretations of the controlling rules, and discusses the importance of these changes for affected U.S. businesses.

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