EPA Issues Proposed TSCA Title VI Amendments for Comment

EPA issued for comment today a prepublication draft proposed rule that sets forth a number of technical amendments to TSCA Title VI.  According to an email announcement to stakeholders today, EPA stated the purpose of the amendments is to better align with CARB Phase 2 and provide greater clarity on the application of certain requirements.  EPA provided the following list of technical amendments that are included in the proposed rule:

  • Removing annual correlations between the Third-Party Certifiers (TPC’s) chamber and the mill quality control (QC) chamber;

  • Allowing equivalence on like size or similar model chambers at TPC lab and mill;

  • Averaging of emission test results from quarterly testing;

  • Establishing testing emission ranges;

  • Allowing for equivalence only if mill uses TPC to conduct all testing;

  • Updating correlational coefficients and “r” value alternatives;

  • Updating the notification of exceedance of quality control limit;

  • Updating NAF and ULEF exemption testing requirements;

  • Updating to the ISO 17025-2017 and 17011-2017 voluntary consensus standards;

  • Updating text in the non-complying lot provisions;

  • Clarifying that labels on compliant products are required at point of entry in the U.S.; and

  • Clarifying the June 1, 2018 manufactured-by date following the court ruling in 2017.

EPA has set the comment period for 30 days, which will begin once the proposed rule is published in the Federal Register.  CPA will review the draft closely and provide detailed, written comments that are aligned with our previous positions expressed in several comment letters and in testimony during the July 28 public stakeholder meeting.  See Prepublication Draft Rule.  More Info: Jackson Morrill 


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