NACD Files Comments Expressing Concerns About EPA's Proposal to Amend TSCA Inventory Reporting Requirements

Oct 13, 2010, 11:11 ET from National Association of Chemical Distributors (NACD)

ARLINGTON, Va., Oct. 13 /PRNewswire-USNewswire/ -- NACD filed comments yesterday expressing concerns about the Environmental Protection Agency's (EPA) sweeping proposal published on August 13 to amend the Toxic Substances Control Act (TSCA) Inventory Update Reporting (IUR) requirements. In the comments, NACD expressed concerns about provisions of the proposal that would require production and import volumes to be reported retroactively to 2006; lower the threshold for reporting processing and use data for both manufacturers and importers from 300,000 to 25,000 lbs.; require much more detailed processing and use information, including the number of commercial workers likely to be exposed; change the current "readily obtainable" reporting standard to "known or reasonably ascertainable by;" require joint reporting of chemical identity information with foreign suppliers; and hold both toll manufacturers and their contracting companies liable if no report is filed.


The comments also urged EPA to delay implementation of all of the increased reporting requirements until after the 2011 reporting cycle. "NACD believes that it is simply not feasible to implement the proposed new IUR requirements in time for the 2011 reporting deadline. EPA is proposing sweeping changes to IUR reporting. It is already ten months into the final collection year for 2011 reports, and making significant changes at this point are not realistic. Requiring the collection of data in every year since the last IUR in 2006, eliminating the 300,000 lb. threshold for use and exposure data, and changing the standard from 'readily obtainable' to 'reasonably ascertainable' with no relief in timeframes is unreasonable," wrote NACD Vice President of Government Affairs Jennifer Gibson in the comments.

For a copy of the comments, go to

For a copy of the proposed rule, go to

NACD and its over 380 member companies are vital to the chemical supply chain providing products to over 750,000 end users. They make a delivery every six seconds while maintaining a safety record that is more than twice as good as the safety standards set by DOT. NACD members are leaders in health, safety, security, and environmental performance through implementation of the Responsible Distribution, established in 1991 as a condition of membership and is a third-party verified management practice. For additional information on our members, their safety record or NACD, visit NACD's website —

CONTACT:  Matthew Glaser of the National Association of Chemical Distributors (NACD), +1-703-527-NACD (6223)

SOURCE National Association of Chemical Distributors (NACD)