3E Company, a leading provider of environmental health and safety (EH&S) compliance and information management services, today announced the availability of a new suite of Chemical Data Reporting (CDR) services. The new services align with the Environmental Protection Agency’s (EPA) recently issued final CDR Rule, which was previously known as the Inventory Update Reporting (IUR) Modifications Rule. Access to reliable support will be instrumental in navigating the new rule and its many complexities, including those related to the EPA’s intent to reduce the number Confidential Business Information (CBI) claims.
The new CDR Rule enables the EPA to collect and publish data on the manufacturing, processing, and use of chemical substances on the Toxic Substances Control Act (TSCA) inventory list. The reporting includes data on chemical substance production volumes, manufacturing sites, and use. EPA’s intention to publish submitted CDR data that is not considered CBI further complicates the issue.
Changes for 2012 Reporting
The CDR Rule includes several notable changes to the IUR Rule. The reporting frequency has reverted from five years to four years. Information about 2011 manufacturing, processing, and use and information about 2010 production volume must be reported. In addition, the industry will now have a submission period of five months for reporting data (February 1 to June 30, 2012).
Under the final rule, manufacturers and importers are required to:
- report if the production volume of a chemical substance meets or exceeds the 25,000-pound threshold during the principal reporting year (i.e., calendar year 2011)
- provide upfront substantiation for each processing and use data element claimed as CBI. Submitters cannot claim those data elements as confidential when they are identified as “not known to or reasonably ascertainable by”
- use e-CDRweb, the EPA’s electronic reporting tool, to submit all CDR information through the Internet
3E Company’s new suite of CDR services can streamline the process and includes the following:
- CDR regulatory support (inventory update report) — review of the September 6, 2011 Final Rule CDR requirements and notification of relevant changes in definitions, scope, thresholds, schedule, and exemptions
- definition of rules and processes — review of current mechanisms for tracking volumes and other information required for imported and manufactured products and materials at the substance level, as well as definition of reporting processes
- inventory searches —review of inventory and determination of which chemicals are affected and which are exempt
- data compilation — identification of required chemical information, including identity, site, volume, use categorization, production, marketing, and industry codes
- data confirmation — review of inventory and determination of whether any required information needs tracking, along with requisite recommendations
- on-site support — orientation, training, collaboration, and review of reportsCDX registrations — support registrant registrations and provide requisite guidance
- complete reports – eCDRweb — complete Form U
- documentation and filing — collate and compile supporting documentation for regulated materials, and provide submission support for hard copy records
“The EPA’s new CDR requirements point to the critical need for effective compliance-data management for inventories, products, and substances,” said Betty Hicks, manager, Co-Authoring Operations at 3E Company. “In addition to managing compliance with CDR requirements, corporate EH&S, product stewardship, and legal staff will need to decide whether they will proactively declassify substances or try to substantiate confidentiality claims. Rights to confidential business information may be challenged as the EPA expands the scope of these regulatory requirements. We’ve developed our new CDR services with these challenges in mind.”
“As a trusted provider of global regulatory data and expertise, 3E is uniquely positioned to support our customers on the complex information demands arising from CBI and CDR requirements,” added Hicks.
About 3E Company
3E Company, a subsidiary of Verisk Analytics (Nasdaq:VRSK), offers a comprehensive suite of data, products, and services for environmental health and safety (EH&S) compliance management. This solutions suite addresses the entire chemical life cycle and includes regulatory research; MSDS authoring, distribution, and management; transportation; emergency response; training; regulatory reporting; and hazardous waste management. 3E provides an industry-leading combination of a 24/7/365 EH&S mission-control call center and the world’s premier hazardous substance database of global regulatory and compliance information. The company was founded in 1988 and is headquartered in Carlsbad, California, with additional operations in Canton, Ohio; Bethesda, Maryland; Kingsport, Tennessee; Montreal, Quebec; and Copenhagen, Denmark. For more information on 3E Company, visit www.3ecompany.com.