Nanotechnology and TSCA Reporting

(Resisting the urge to make an obscure Mork and Mindy reference – or an even more obscure mention of Fantastic Voyage…)

EPA has issued guidance on complying with the new Nanotechnology Reporting and Recordkeeping Rule, published in January with an effective date that has been extended to August 14, 2017. The rule establishes one-time reporting and recordkeeping requirements for certain chemical substances when they are manufactured or processed at the nanoscale (i.e., materials that are solids at standard temperature and pressure; that are manufactured or processed in a form where any particles, including aggregates and agglomerates, are in the size range of 1-100 nanometers – that’s one to one hundred billionths of a meter – in at least one dimension) for the purpose of demonstrating one or more unique, size-dependent properties that would not be present in larger materials. Reporting for existing nanomaterials that have been manufactured or processed in the three years prior to the effective date will be due by August 14, 2018.

Continue reading “Nanotechnology and TSCA Reporting”

Alert! TSCA Chemical Data Reporting Deadline Nears

>> UPDATE: EPA has announced that the deadline for Chemical Data Reporting submissions has been extended to October 31.

The period for submission of 2016 reports required under the Toxic Substances Control Act (TSCA) Chemical Data Reporting rule ends on September 30th. The reporting requirement applies to any person that manufactured or imported, in any year from 2012 to 2015, listed chemicals in more than threshold amounts (generally 25,000 pounds, though a lower threshold of 2,500 lbs has been set for toxic chemicals that are subject to certain TSCA actions), unless exempted as a small manufacturer. Some 80,000 chemicals are on the TSCA list.

A sample reporting form (“Form U”) and instructions to help guide you through the reporting process can be found at the EPA Chemical Data Reporting website. The reports must be submitted online, using the EPA’s Central Data Exchange system ( You will need to add the program area CSPP: Submissions for Chemical Safety and Pesticide Programs to your profile on CDX to activate this reporting option, if you haven’t already done so.

If you have questions about the Chemical Data Reporting requirements or submission process, please contact T. Cozzie Consulting for immediate assistance.