Washington: HSE initiatives to watch

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Courtesy of Bergeson & Campbell, P.C.

On Nov. 25, 2008, the U.S. Environmental Protection Agency (EPA) released for public comment two background discussion documents, oneon EPA’s Toxic Substances Control Act (TSCA) Inventory Reset initiative and the other on EPA’s proposed approach for the Inorganic High Production Volume (IHPV) Challenge Program. Both initiatives are important, and readers are urged to monitor these programs carefully as they evolve, for many reasons.

Inventory Reset Disucssion

There are currently almost 84,000 chemicals on the TSCA inventory, with almost 22,000 chemicals added to the inventory through new chemical review since 1979. In 1986, EPA promulgated the Inventory Update Rule (IUR) requiring chemical manufacturers to update production volume data for certain chemicals on the inventory. At least one problem EPA has identified is that because the IUR does not require reporting for all chemicals on the inventory, it is unclear which chemicals not subject to IUR reporting are in commerce at a given point in time.

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