TSCA EnSafe Webinar
How well do you know your facility? That is the first and most important step to knowing what, if any, Toxic Substances Control Act (TSCA) rules apply to you. In this seminar, Adam Wiseman and Tiffany Thomas discussed some of the best ways to navigate TSCA and how it could apply to you.
It was strongly emphasized that knowing how to use the EPA CDX (Central Data Exchange) portal and resources is key to understanding what applies to you. Do you meet the threshold for reporting limits? Many chemicals have a threshold volume associated with them, some as high as 25,000 lbs. Knowing your chemicals and the associated thresholds could determine if you even need to report at all.
Do you have a chemical that falls under TSCA reporting? Not all chemicals require TSCA reporting. Knowing what chemicals or combinations you have and are working with, is another key component of knowing what reporting is required of your facility.
Are you dealing with an article or a product? An example of this is brake fluid. If you import brake fluid in containers or drums, then this is a product that is intended to be used in a finished article (i.e., a vehicle). If you import a vehicle with brake fluid in it, then it is in an article that needs it to function properly, and the brake fluid is not intended to be removed. It is a part of the article/finished product and would not need to be reported.
The bottom line is to know your facility, then know your triggers (i.e., how much in revenue, production, volume, origin, manufacturing, importing, how is it used, product users (children), is it liquid, gas, or solid?). All of these are examples of triggers that could make reporting necessary. Familiarity with your facility and the EPA SRS (Substance Registry Service) are the key aspects to get these questions answered. So, as difficult or annoying as it can be, take the time to know your facility and all the processes that are happening and the chemicals used. Then you will be equipped to check to see if any triggers have been activated for your facility.