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EPA Webinar Further Clarifies TSCA Risk Analysis Fee Obligations

Yesterday, EPA hosted a webinar to clarify TSCA Risk Analysis fee obligations following the recently announced changes to the list of responsible stakeholders.  As reported in @the edge, EPA announced on March 25 that it intends to initiate a new rulemaking process that will exempt from TSCA’s self-identification requirement stakeholders that: 

  • Import the chemical substance in an article;

  • Produce the chemical substance as a byproduct; and

  • Produce or import the chemical substance as an impurity.

EPA simultaneously issued a “No Action Assurance” (NAA) for the above three stakeholder categories, meaning that the Agency will not pursue enforcement action against these stakeholders for failure to self-identify for the period until the exemption rulemaking goes into effect.  Only those companies that “manufacture, produce or import the high-priority chemical” are now responsible for self-identification and payment of the $1.35 million TSCA Risk Analysis fee per chemical. 

Notably, EPA provided that some stakeholders in the above three categories may still need to take action on the EPA’s public reporting docket, known as the CDX system.  Specifically, EPA provided the following direction: 

  • If not on the preliminary list of responsible stakeholders published on January 27 and not yet self-identified in CDX - No action expected or required;

  • If on a preliminary list, but have not yet self-identified in CDX – Check the box entitled “No Manufacture” on the CDX system; or 

  • If already self-identified in CDX - Amend response by checking the box entitled “No Manufacture.”

All reporting must still take place before the May 27 deadline.  Furthermore, for companies with more than one facility on EPA’s preliminary list, the agency clarified that only the parent company is required to report on the CDX system.  However, the parent company must make clear it is reporting on behalf of all listed facilities.  Additionally, EPA encouraged the parent company to submit a short comment to the docket on Reg.gov noting which facilities are included.

CPA encourages all members to review closely EPA’s latest guidance on reporting requirements, which may be found in the April 16 slide deck on the Agency’s website.  If necessary, other comments may also be submitted to Reg.gov through EPA’s TSCA Fees website.  See EPA Slide Deck; Preliminary List of Stakeholders; EPA No Action Assurance; TSCA Fees Website.  More Info: Jackson Morrill

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