3E Company launches new Chemical Data Reporting services
3E Company, a leading provider of environmental health and safety (EH&S) compliance and information management services, today announced the availability of a new suite of Chemical Data Reporting (CDR) services. The new services align with the Environmental Protection Agency’s (EPA) recently issued final CDR Rule, which was previously known as the Inventory Update Reporting (IUR) Modifications Rule. Access to reliable support will be instrumental in navigating the new rule and its many complexities, including those related to the EPA’s intent to reduce the number Confidential Business Information (CBI) claims.
The new CDR Rule enables the EPA to collect and publish data on the manufacturing, processing, and use of chemical substances on the Toxic Substances Control Act (TSCA) inventory list. The reporting includes data on chemical substance production volumes, manufacturing sites, and use. EPA’s intention to publish submitted CDR data that is not considered CBI further complicates the issue.
Changes for 2012 Reporting
The CDR Rule includes several notable changes to the IUR Rule. The reporting frequency has reverted from five years to four years. Information about 2011 manufacturing, processing, and use and information about 2010 production volume must be reported. In addition, the industry will now have a submission period of five months for reporting data (February 1 to June 30, 2012).
Under the final rule, manufacturers and importers are required to:
• report if the production volume of a chemical substance meets or exceeds the 25,000-pound threshold during the principal reporting year (i.e., calendar year 2011)
• provide upfront substantiation for each processing and use data element claimed as CBI. Submitters cannot claim those data elements as confidential when they are identified as “not known to or reasonably ascertainable by”
• use e-CDRweb, the EPA’s electronic reporting tool, to submit all CDR information through the Internet
3E Company’s new suite of CDR services can streamline the process and includes the following: