The U.S. Environmental Protecting Agency (EPA) is amending the Toxic Substances Control Act (TSCA) Chemical Data Reporting (CDR) regulations to extend the September 30, 2024 submission deadline for 2024 reports to November...more
The U.S. Environmental Protection Agency (EPA) is modifying the Toxic Substances Control Act (TSCA) regulation imposing reporting and recordkeeping requirements for perfluoroalkyl and polyfluoroalkyl substances (the Rule) to...more
The U.S. Environmental Protection Agency (EPA) has finalized a one-time reporting rule regarding the manufacture (including import) of per- and polyfluoroalkyl substances (PFAS). Despite heavy industry opposition, obligated...more
Key Takeaways -
What is happening? The U.S. Environmental Protection Agency (EPA) has finalized a rule requiring asbestos manufacturers, importers, and processors to report certain asbestos exposure-related information....more
Last year was busy with regulatory actions under the Toxic Substances Control Act (TSCA). This year promises to be even busier. Companies should make sure they are paying attention, including to comment deadlines for proposed...more
The U.S. Environmental Protection Agency's (EPA) June 2021 proposal of a Toxic Substances Control Act (TSCA) reporting rule targeting manufacturers of per- and polyfluoroalkyl substances (PFAS) sparked a major outcry from...more
A year into the Biden Administration’s implementation of the 2016 amendments of the Toxic Substances Control Act (TSCA), EPA is planning an ambitious suite of actions under sections 4, 5, 6, 8, 14, and 23. Companies and trade...more
More than four years after finalizing reporting requirements for the manufacture, import, export, processing, and distribution in commerce of elemental mercury and mercury-added products, EPA has eliminated an exemption for...more
EPA has issued a prepublication version of a final rule to extend the submission deadline for the TSCA Health and Safety Data Reporting rule to December 1, 2021 for the 20 High Priority Substances, and to January 25, 2022 for...more
Section 8(d) of the Toxic Substances Control Act (TSCA) had been effectively a dead provision of TSCA for over a decade. EPA has just revived it by adopting an immediate final rule mandating the submission of health and...more
A federal court has ordered EPA to make extensive changes to its Chemical Data Reporting rule (CDR) with respect to asbestos reporting. While the ruling in ADAO v. Wheeler is limited to CDR reporting of asbestos, it sets the...more
Inventory Reset reporting under the Toxic Substances Control Act (TSCA) seems like years ago, because it was – Form A’s were due February 7, 2018 for manufacturers and October 5, 2018 for processors. Companies are now likely...more
During Inventory Reset in 2017-2018, did your company assert on Form A confidentiality claims for chemical identities on the confidential Toxic Substances Control Act (TSCA) Inventory? If so, you risk having EPA make those...more
If your facility has a significant accidental release of a hazardous chemical, your team will need to respond immediately, particularly if the release threatens the public, workers, or the environment. But don’t forget to...more
For the first time in over 30 years, the Securities and Exchange Commission (SEC) has proposed amendments to modernize its regulation requiring registrants to report environmental penalties and certain other environmental...more
EPA faces many TSCA statutory and regulatory deadlines for actions in 2019 and 2020. It has also announced plans to take numerous actions not subject to such a deadline. Industry should anticipate upcoming developments and be...more
Every four years, domestic manufacturers and importers of chemicals must report to the Environmental Protection Agency under the Chemical Data Reporting rule (CDR). The next reports are due in 2020, with 2019 as the principal...more
OSHA has finalized a rule that rescinds the requirement for establishments with 250 or more employees to electronically submit their OSHA Form 300 (Log of Work-Related Injuries and Illnesses) and Form 301 (Injury and Illness...more
The Occupational Safety and Health Administration (“OSHA”) made important announcements this month regarding the electronic submission of injury and illness data. The first of these announcements took a big step back from...more
OSHA recently issued a Notice of Proposed Rulemaking that proposes to rescind the requirement for establishments with 250 or more employees to electronically submit their OSHA Form 300 (Log of Work-Related Injuries and...more
The composite wood product industry may face an earlier compliance deadline under EPA’s Formaldehyde Emission Standards for Composite Wood Products (Standards) than the deadline currently set by EPA. On February 16, 2018, a...more
EPA has extended the December 26, 2017 deadline for comments on its proposed rule on reporting obligations relating to mercury, mercury compounds, and mercury-added products until January 11, 2018. The proposed rule was...more
On November 24, 2017, OSHA published a final rule in the Federal Register delaying the initial compliance deadline for the electronic submission of worker injury and illness logs to December 15, 2017. By December 15, all...more
The Environmental Protection Agency (EPA) released the Working Guidance on EPA’s Section 8(a) Information Gathering Rule on Nanomaterials in Commerce (Guidance) on August 14, 2017. EPA developed the final Guidance based on a...more
Virtually all manufacturers and importers of chemicals for the past 11 years are now subject to a new TSCA reporting requirement known informally as the TSCA Inventory Reset. Reports are due by February 7, 2018. All...more