More Changes in Store for IUR Reporting

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Courtesy of Bergeson & Campbell, P.C.

Last month’s column detailed a rulemaking that finalized amendments to the U.S. Environmental Protection Agency’s (EPA) Toxic Substance Control Act (TSCA) Section 8(a) Inventory Update Rule (IUR). This month’s column takes a look at additional rule-related actions the agency said it expects to take in the future, as well as the implications of these changes for chemical facilities.

Future actions

Standard operating procedure (SOP) for obtaining partial exemptions. EPA intends to issue an SOP/guidance document providing additional details about how to add chemical substances to the list of substances for which a partial exemption applies.

Guidance on completing Form “U.” EPA is preparing a guidance document with specific reporting instructions to assist in completing Form U. The agency also intends to conduct workshops to help IUR submitters understand the new reporting requirements. EPA said it would seek comment on the revised Form U before issuing it in final for users in 2006.

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