2016 Chemical Data Reporting in Full Swing
Posted: August 29th, 2016Authors: Colin M.
In our February blog post “Brace Yourself – 2016 Chemical Data Reporting is Coming”, we talked about 2016 being a reporting year in the Toxic Substances Control Act (TSCA) Chemical Data Reporting (CDR) rule cycle. This report is due every four years and requires that manufacturers and importers of TSCA substances above certain quantity thresholds submit a report to U.S. EPA. It has been six months since our original blog post and the CDR program is now in full swing. The submission period for the 2016 reporting cycle began June 1, 2016 and we have been busy helping our clients identify reportable substances, compile the required information, and navigate changes to reporting requirements from the 2012 CDR cycle.
With the September 30 reporting deadline fast approaching, now is the time to kick CDR into full gear for your facilities. Here are some key things you should consider as you tackle the 2016 CDR:
1. Registration in CDX:
Most facilities submitted their 2012 CDR reports via a paper form. However, this is no longer an option for the 2016 reporting cycle and instead, facilities are required to report electronically via U.S. EPA’s Central Data Exchange (CDX). Making sure you are properly set up to report through CDX should be one of the first steps in the CDR process.
2. Identifying Reportable Substances:
The 2012 report for your facility is a good starting point for identifying substances that need to be reported in 2016. However, there are few things to keep in mind:
a. Changes to processes, products, and suppliers that may result in new substances that need to be reported should be thoroughly reviewed.
b. For the 2016 CDR cycle, U.S. EPA is now requiring that reportable substances be identified based on the amount manufactured or imported during any calendar year between 2012 and 2015. This is different from the 2012 CDR cycle where applicability was based only on calendar year 2011 production and import volumes.
c. Also new for the 2016 CDR is the introduction of a reduced reporting threshold of 2,500 pounds for substances “subject to certain listed TSCA actions”. This reduced threshold has the potential of adding a number of new substances to 2016 CDR reports.
3. Compiling Processing and Use Information:
Once the reportable substances are identified, processing and use information may need to be compiled for the report. Facilities should note that for the 2016 CDR, this information is now required for substances imported or manufactured in quantities of 25,000 pounds per year or more (or 2,500 pounds or more for those substances under the reduced reporting threshold). This represents a significant decrease from the 2012 CDR threshold of 100,000 pounds for reporting use information and will lead to many more substances for which use information needs to be reported.