Bergeson & Campbell, P.C.

Bergeson & Campbell, P.C.

TSCA Mercury Inventory: Dec. 26 Deadline for Comments on Proposed Reporting Requirements Approaching


Source: Bergeson & Campbell, P.C.

As previously reported in our TSCAblog® item on October 26, 2017, the U.S. Environmental Protection Agency (EPA) proposed triennial electronic reporting requirements pertinent to the supply, use, and trade of mercury in the United States. 82 Fed. Reg. 49564.  The 2016 amendments to the Toxic Substances Control Act (TSCA) require EPA to establish periodic mercury reporting requirements for any person that manufactures mercury or mercury-added products or otherwise intentionally uses mercury in a manufacturing process to assist in the development of an inventory of mercury and other recommended actions. These other actions reportedly include potentially revising federal law or regulations to achieve further reductions in mercury use.

Under the proposed rule, EPA proposes to require reporting on the manufacture, import, distribution in commerce, storage, and export of mercury. EPA is directed by new TSCA to refrain from requiring reporting related to the generation, handling, or management of mercury-containing waste, unless mercury is recovered in the management of such waste. The proposed rule aims to narrow data gaps and limitations encountered in the EPA’s historic reliance on publicly available data on the mercury market in the United States. Additionally, the information provided under the proposed rule would be used by the U.S. government to assist in its implementation of the Minamata Convention, a multilateral environmental agreement that addresses the supply, use, and trade in mercury. Comments on the proposal are due by December 26, 2017.

This memorandum provides more information on how EPA specifically defines mercury and mercury supply, use, and trade; the rule’s coordination with existing reporting programs; persons who must report; and the frequency of inventory publication and data collection.

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