The U.S. Environmental Protection Agency recently released a document that addresses a series of 18 industry scenarios and questions related to the agency’s new Chemical Data Reporting (CDR) rule. The scenarios were originally proposed to EPA by Bergeson and Campbell (B&C) in their efforts to represent broad segments of the regulated community. EPA has stated that the goal of their document is to help industry comply with the requirements of the CDR rule, however they stress that it is not a substitute for that rule, nor is it a rule itself. Furthermore, it does not impose legally binding requirements on the regulated community or on EPA.
Despite these wide caveats, the document is useful in understanding the mindset of regulators as they seek to inform on compliance expectations. The document and other EPA CDR compliance information can be found HERE.
Last August EPA issued the final Toxic Substances Control Act (TSCA) Chemical Data Reporting (CDR) rule, previously referred to as the Inventory Update Reporting (IUR) Modifications Rule. It expanded the requirements for reporting data on production volume, use, and exposure for many chemicals widely used in commerce, and makes electronic reporting mandatory. Its purpose is to facilitate the collection of quality screening-level, exposure-related information on chemical substances and to make that information available for use by EPA. The new rule seeks to make, to the extent possible (due to data confidentiality claims), this same information available to the public.