With the recent release of the 2016 Chemical Data Reporting (CDR) dataset and the initial interim list of active substances released with the June 2017 copy of the Toxic Substances Control Act (TSCA) Inventory (Inventory), the magnitude of effort that will be needed to comply with the Section 8(b)(4) Inventory notification process is becoming clear (see our June 6, 2017, memorandum “Preparing for the Inventory Reset: It Is Not That Easy”). Even with the U.S. Environmental Protection Agency’s (EPA) decision to designate as “active” substances that were subject to Notices of Commencement during the look-back period, manufacturers, importers, and processors must carefully review records to determine which of the over 72,000 substances not included on the current interim active list were manufactured, imported, or processed in the ten-year look-back period and waste no time in preparing to meet their obligations.
New TSCA requires that EPA review and make determinations on all new chemical notifications submitted to EPA. These changes, which were effective as of the June 2016 enactment of the amended law, presented implementation challenges for EPA with the result that a backlog of unresolved premanufacture notification (PMN) cases accumulated as discussed in the June 12, 2016, BBNA webinar “Reviewing New Chemicals under Amended TSCA: Impact on Innovation.” EPA committed to and has largely eliminated this backlog. The panel will provide an update on EPA’s progress in addressing the backlog and discuss other emerging new chemical issues.
The webinar will be presented by a panel of former EPA officials and seasoned regulatory professionals, who will discuss how to prepare for the forthcoming Inventory notification deadlines and update attendees on EPA’s new chemical review process. The webinar will consist of 75 minutes of presentation, followed by a 15 minute Q&A period.
- TSCA Section 5 Inventory notification reporting requirements and strategies;
- How to recognize and avoid pitfalls when reporting;
- Current state of play of EPA’s new chemicals review process; and
- What you can do now to ensure your chemicals and chemical products get to market and stay there.
Reporter, Bloomberg BNA
Jeffery Morris, Ph.D.
Director, Office of Pollution Prevention and Toxics, EPA
Lynn L. Bergeson
Managing Partner, Bergeson & Campbell, P.C.
Charles M. Auer
Senior Regulatory and Policy Advisor, Bergeson & Campbell P.C.
Richard E. Engler, Ph.D.
Senior Chemist, Bergeson & Campbell, P.C.
Lawrence E. Culleen
Partner, Arnold & Porter Kaye Scholer
CLE credit is available in many jurisdictions; check the webinar registration page for details.
Register for “TSCA Hot Topics: Inventory Notification and Strategies for Complying, and Update on Section 5” online. This is a complimentary webinar; there is no cost to register.