The recent signing of the Frank R. Lautenberg Chemical Safety for the 21st Century Act has brought about a long overdue reform of the Toxic Substances Control Act (TSCA). But despite the buzz surrounding TSCA reform and how the Environmental Protection Agency (EPA) will implement the new legislation going forward, chemical manufacturers and importers must keep their eyes on the here and now—and the here and now includes the TSCA Chemical Data Report (CDR).
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Existing TSCA regulations under 40 CFR 711 require manufacturers and importers to report information on the types, quantities, and uses of chemical substances manufactured domestically or imported into the United States above certain thresholds and spanning a 4-year period. The current CDR (i.e., the 2016 CDR that contains data from 2012–2015) must be submitted at any time during the reporting window, which spans from June 1 to September 30, 2016. So depending on how you look at it, the reporting window is either almost half-closed or more than half-open. Either way, it is time to complete the 2016 CDR and get it to the EPA.