Webinar: EPA's Proposed TSCA Inventory Reset Rule

On January 13, 2017, EPA issued its long-awaited proposed TSCA Inventory “Reset” rule as mandated under the recent TSCA amendments.  The proposal would require:

• Within 180 days of the date of publication of the final rule manufacturers and importers must notify all substances they manufactured or imported between June 21, 2006 and June 21, 2016 unless already reported by another company for the 2012/2016 CDR (applies only to substances not claimed confidential on the CDR) or that are exempt from reporting.  Polymer manufacturers and importers will be primarily impacted along with manufacturers and importers of substances produced below CDR thresholds and companies that submitted CDR reports on substances on the confidential version of the TSCA Inventory.
• Within 360 days of the date of publication the final rule processors have the opportunity to report substances that they processed during the relevant 10- year period to ensure their activities are not disrupted in the event no manufacturer or importer reports a substance.
• If a substance is not reported, it is considered “inactive” and a notification will need to submitted 30 days before actual manufacturing or processing begins. 
•  Chemicals added to the Inventory on or after June 22, 2016 are automatically designated “active” and are not subject to notification requirements.
• Reporting will be via the CDX system and confidentiality claims will need to be made and substantiated.

Keller and Heckman partners Herb Estreicher and Tom Berger reviewed key aspects of the proposal and gauge interest among participants on a collaborative effort to prepare comments which are due March 14, 2017.

For a copy of this webinar, please contact marketingdepartment@khlaw.com.