Chemical Data Reporting (CDR), like the Olympics, occurs every four years, and then most facilities move on to more pressing environmental, health and safety (EHS) matters.
Under the Toxic Substances Control Act (TSCA), EPA requires manufacturers (including importers) to provide EPA with information on the production and use of chemicals in commerce. The reporting threshold is generally 25,000 pounds in a reporting year; a 2,500-pound threshold applies to those chemicals under TSCA “special actions” in effect on the June 1, 2024 start of reporting season.
For each reportable chemical above the threshold (for even one of the four years in the cycle), CDR data must include information on the manufacture (including import), industrial processing and use, and consumer and commercial use. For the 2024 CDR, the principal reporting year is calendar year 2023. Manufacturers (including importers) need to report full manufacturing, processing and use information for 2023 only and production volume information for calendar years 2020, 2021, 2022 and 2023.
In other words, 2023 is the reporting year for which facilities need to contemplate the customer base and how chemicals are used—the 2020-2022 data is simply “how much” and “what form.”
Prior planning brings success!
Why bring up TSCA CDR 9 months before the reporting season even starts? Planning now will set you up for success at reporting time. Be prepared by considering these key questions:
- Did you remember to include CDR in your 2024 budget?
- Do you have standards or procedures for how the reporting data is collected, reviewed and verified?
TRC Can Help
TRC will bring more TSCA CDR insights over the next several months, leading up to the opening of 2024 reporting season on June 1, 2024. Continue to visit the TRC News & Insights webpage for updates. For more information regarding TSCA CDR reporting, please contact our expert below.
Mark Robinson
Mark B. Robinson, PE, CHMM, CPEA is the National Service Leader for Chemical Management and Reporting Services for TRC and is located in the Atlanta area. He has over 30 years in consulting and industry EHS experience. He has managed a wide variety of industrial sector projects and programs, including EHS compliance auditing for airbag manufacturers, dairy and food manufacturing/distribution and pulp/paper mills; managing a portfolio of SPCC/FRPs for telecom and petroleum terminals; and complex regulatory reporting across various industries.
For the 2020 TSCA CDR season, he supported reporting for the oil and gas industry including refining, asphalt, and import/export; pulp and paper mills; cement plants; and metals smelting industries.
Contact Mark at MBRobinson@trccompanies.com.