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EPA Issues Guidance on New Mill Start-Up and Experimental Trial Runs

EPA has issued guidance under its “Frequently Asked Questions” section on “domestic” new mill start-up procedures and experimental trial runs.  The new guidance permits new U.S. mills, or mills undergoing a restart in the U.S., to conduct lot-by-lot testing at the mill site while the mill is completing its correlation curves to achieve TSCA Title VI certification.  Tested lots that pass the TSCA Title VI emissions levels may be labeled and sold into the marketplace.  Mills wishing to participate in this program would need to adhere to all of the additional panel producer requirements. 

With regard to experimental trial runs, EPA has determined that products from either resin trials or new product tests would not meet the definition of “panel,” which excludes items produced during research and development.  Therefore, samples could be transported to TPCs for testing without running afoul of other sections of the Regulation, including most notably the reporting obligations for non-complying events and running averages for purposes of reduced quality control testing. 

CPA had submitted comments in October 2017 requesting that EPA address both of these issues.  See EPA Guidance.  More Info: Jackson Morrill and Gary Heroux

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