Toxic Substances Control Act (TSCA) Services

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3E Company provides support for the complex and time-consuming tasks associated with regulatory compliance for the Toxic Substances Control Act (TSCA). Outsourcing this process to a team of experienced regulatory professionals that is actively involved and engaged in these activities on a daily basis can be a highly efficient and effective way to address the challenges associated with ensuring compliance with chemical control laws.

TSCA services can be performed as either a defined project or on a scheduled, on-going basis and range from fully outsourcing TSCA compliance to project-based, function-specific areas.

Support You Need, When You Need It

3E's team of TSCA Compliance professionals can perform the following:

  • Regulatory Tracking - Monitor EPA activity, federal register notices, final rules, enforcement activities to review and direct compliance measures
  • Spearhead TSCA Compliance - Interface with the client's management team, regulatory personnel and others to direct TSCA Compliance program
  • TSCA Section 5 - New Chemical Substance Compliance Support, Premanufacture Notice (PMN) requirements (Low volume exemption (LVE)), Notice of Commencement (NOCs), bona fide letters
    • Consulting with client
    • Consulting with EPA - PNCs
    • Review of test data and other supporting documentation
    • Collaboration with customer chemists and regulatory personnel, industrial hygiene and other professionals
    • Completion of Form 7710-25
    • QC Proof of submission
    • Duplication of supporting documents
    • Sanitization of PMN
    • Support Registrant Role in Submission of Notification
    • Guidance on Fee Filing (3E will advise on process)
    • Notice of commencement
  • Significant New Use Rules (SNUR)
  • Interpret and compliance program
  • Significant New Use Notice (SNUN)
  • Notify EPA 90 days before activity
  • Chemical Data Reporting (CDR)
    • Review inventory update report requirements 2012 – 2016 as per most recent amendment
    • Review current mechanisms for tracking volumes and other required information of imported and manufactured products and materials at substance level
    • If required information is not currently tracked, recommendations will be made on the best way to do so
    • Complete report for signature and submission
  • TSCA 8b Status Reviews and Certifications
  • TSCA 8c and 8e Review and Submission
  • Import Certifications - TSCA Stamp and FIFRA Notice of Arrival of Pesticides
    • Review incoming shipments for TSCA Import Status
    • Provide proper TSCA Import Certification paperwork for all shipments coming into US from overseas
    • If necessary, file FIFRA Notice of Arrival of Pesticides forms with EPA
  • TSCA 12(b) Export Notification Support
    • Review raw materials and mixtures for presence of substances subject to TSCA 12(b)
    • File any necessary Export Notifications with EPA
  • Exemptions Assessments and Certifications: R&D, Polymer, LoRex
  • CAS RN Number Application
    • CAS Inventory Expert Services Purchase Order
    • Complete required documentation
  • Global Inventory Status of New Ingredients and Finished Goods
  • Training at all levels
  • On–site self assessments and audit preparedness

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