Brace Yourself – 2016 Chemical Data Reporting is Coming

2016 is special not only because it is a leap year, but it is also a reporting year in the Toxic Substances Control Act (TSCA) Chemical Data Reporting (CDR) rule cycle. Every four (4) years (the previous report was required in 2012), manufacturers of TSCA regulated chemicals must evaluate if their facility exceeded the reporting threshold of the CDR rule. With certain exceptions, reporting is required in 2016 if a facility’s annual production volume (PV) in 2012, 2013, 2014, or 2015 was at least 25,000 pounds. This link will help you evaluate if your facility is in an industrial sector regulated by the CDR rule. How do you know if your facility submitted a CDR report in the past? First, keep in mind that this rule was previously known as the Inventory Update Reporting (IUR) rule, so check your files for documents with this description, or for a reference to Form U, which is the name of the form that is prepared and submitted. You can also search U.S. EPA’s Chemical Data Access Tool (CDAT) by chemical name or company.

The submission period for the 2016 CDR report begins on June 1, 2016 and ends on September 30, 2016. As is the trend these days, you are required to prepare and submit a Form U for each reportable chemical electronically via U.S. EPA’s Central Data Exchange (CDX). You can access CDX here, and register under the program “Submissions for Chemical Safety and Pesticide Programs (CSPP)”. If you were previously registered on CDX for e-TSCA, e-PMN, or TRI, you are able to add the CDR reporting flow to your current registration. Once you are registered, you can access e-CDRweb to complete and submit a Form U.

Whether you are new to the CDR rule, or because it has been since 2012 when you last thought about it, do not wait until September 29, 2016 to try to submit your report. While you will not be able to submit before June 1, 2016, the CDR reporting period overlaps with TRI, Title V semiannual monitoring reports, emissions inventory and fee reports, Boiler MACT testing (we hope you read Nick’s blog on this!), and most importantly, summer vacation.