Technical Bulletin
EPA Provides Preview of TSCA Reform Implementation and Milestones 
In a recent webinar, the United States Environmental Protection Agency (EPA) offered a preview of their proposed implementation plan and key milestones for Toxic Substances Control Act (TSCA) Reform.


GZA has been monitoring this significant change to TSCA and are prepared to provide thorough analysis of the potential implications that TSCA Reform may have on regulated industry and the public. GZA's regulatory specialists possess a practical understanding of this legislation, as well as related state and local environmental regulation. GZA is actively assisting its clients by determining the applicability of TSCA Reform as it relates to their activities and anticipating potential new requirements that may impact their chemical management program and overall business.


Below is a brief summary of EPA's plan to implement TSCA Reform are as follows:


Important Dates
  • Mid-September, 2016: EPA to publish initial list of prohibited mercury-based chemicals
  • December 31, 2016: Small Business definition to be reviewed, relative to potential exemptions based on size
  • April 1, 2017: EPA to inventory mercury supply, use, and trade in the US
  • June 2017: EPA must:
  1. Establish a risk-based screening process for evaluating new and existing chemicals,
  2. Publish final rule for inventory of chemicals manufactured/ processed in the previous 10 years. Results will be used to designate active and inactive chemicals on the TSCA Inventory of existing chemicals.
  3. Develop guidance on risk evaluation, and
  4. Establish Science Advisory Board to provide independent advice and expert consultation with respect to the scientific and technical aspects of issues related to implementation of the statute.
  • Early October 2017: Proposed rule for TCE use in spot cleaning and aerosol degreasing.
  • December 2017: Proposed rule for TCE use in vapor degreasing, and MC and NMP use in paint removers
  • December 2017: EPA must be evaluating risks of 10 chemicals, including:
  1. trichloroethylene (TCE)
  2. Methylene Chloride or Dichloromethane (DCM):
  3. HHCB
  4. antimony trioxide (ATO)
  5. Bisphenol A (BPA)
  6. Decabromodiphenyl ether (decaBDE)
  7. Hexabromocyclododecane (HBCD)
  8. Nonylphenols and nonylphenol ethoxylates (NP/NPE)
  9. phthalates
  10. long-chain perfluorinated chemicals (PFCs)

 

About TSCA Reform


In the first major change to TSCA since its original passage in 1976, the "Frank R. Lautenberg Chemical Safety for the 21st Century Act" (a.k.a. TSCA Reform) was signed into law by President Obama in June, 2016. TSCA Reform gives EPA more authority and enforcement power to evaluate new and existing chemicals. The law which received bi-partisan support, paved the way for new risk-based safety standards for chemicals, with clear enforceable deadlines.


The EPA will prioritize over 300 new chemicals for assessment and risk evaluation:
  • Using a new risk-based safety standard, EPA will make a definitive determination regarding "unreasonable risk," management actions, and enforceable deadlines for each chemical evaluated
  • Chemical Manufacturers will be required to provide additional data to the EPA to inform assessments and will bear the cost of assessments.
Other TSCA Reform Components:

  • Routine review of and determination on all new confidentiality claims
  • New fast-track process will address certain persistent, bio-accumulative and toxic chemicals (PBTs)
  • Industry/manufactures is required to report chemicals they manufactured or processed in previous 10 years as part of "active" or "inactive" designation


Please contact GZA for additional information:


Ron Breton, P.E. [email protected]
Marc Hudock, LSRP [email protected]


 
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