Understanding TSCA Inventory Reset Rule

USA

Understanding TSCA Inventory Reset Rule

Little Pro on 2018-11-20

5 Oct 2018 is the last deadline for processers to report the active status of their substances to US EPA under amended TSCA. The US EPA is expected to release a final TSCA inventory soon in which substances will be designated as either “active” or “inactive”. In this article, we will take a look at what this means to you and how to check if a substance is active or inactive.

Background

Amended Toxic Substances Control Act (TSCA) requires EPA to designate chemical substances on the TSCA Chemical Substance Inventory as either “active” or “inactive” in U.S. commerce. The TSCA Inventory Reset Rule requires manufacturers and processers to submit electronic notifications to EPA for chemicals that have been manufactured, imported or processed for non-exempt commercial purposes between June 21, 2006 and June 21, 2016. EPA will use these notifications to distinguish active substances from inactive substances.

Substances designated as "active" on TSCA inventory can be manufactured, imported or processed without any notifications. Substances designated as "inactive" on TSCA inventory must be notified to the US EPA via Notice of Activity Form (NOA-B) 90 days prior to planned manufacture, import or processing. On receiving NOA-B notification forms, EPA will change the designation of the notified chemical substance on the TSCA Inventory from inactive to active.

Substances which are not listed on TSCA inventory at all will continue to be regulated as new chemical substances. New substances will be subject to TSCA section 5 Pre-manufacture Notice (PMN) requirements.

How to Search TSCA Inventory

US EPA has already published an interim version of TSCA inventory with the designation status (active or inactive) of listed chemical substances [last update: April 2018]. The inventory includes 2 parts: public section and confidential section.

TSCAINV_042018: Public section of TSCA inventory. Substances are identified by CAS no,, CA name and status.
PMNACC_042018: Confidential section of TSCA inventory. Substances are identified by EPA accession number , generic chemical name and status.

You may download the latest TSCA inventory in .csv format here.

TSCA Inventory

References

https://www.regulations.gov/document?D=EPA-HQ-OPPT-2016-0426-0070

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