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May 16, 2016

2016 Chemical Data Reporting Webinar Recording Available; Analysis of CDR Enforcement Actions Released

The ACTA Group

To prepare companies for the reporting period for the 2016 Chemical Data Reporting (CDR) rule, June 1 – September 30, 2016, Bergeson & Campbell, P.C. (B&C®) presented a webinar, “2016 Chemical Data Reporting: Don’t Despair; Get Prepared!,” on May 3, 2016.  A recording of the webinar, presentation slides, and a document containing detailed answers to the many questions submitted by webinar participants will be made available to B&C clients and associates who were not able to attend. Contact to request the materials. 

As seasoned regulatory veterans know, CDR applies to manufacturers and importers of chemical substances subject to the Toxic Substances Control Act (TSCA).  But those watching the CDR space know that changes will be implemented in the 2016 reporting cycle, and even experienced CDR submitters may get tripped up on these changes, which include:

  • Expansion of years to report on production volume information;
  • Varied reporting threshold for subject chemicals; and
  • Potential exclusion of reporting exemptions.

The webinar included a review of CDR reporting elements, a highlight of changes that will come into play for 2016, and some helpful hints on how to get prepared.  Moderated by B&C Managing Partner Lynn L. Bergeson, the webinar was presented by B&C professionals Kathleen M. Roberts, Senior Regulatory Consultant, and Richard E. Engler, Ph.D., Senior Chemist.

On May 11, 2016, B&C released a report on recent enforcement actions taken by the U.S. Environmental Protection Agency (EPA) under the CDR rule. B&C reviewed enforcement action data from May 2007 through September 2014 and found 37 different cases involving an allegation of a violation of the CDR rule. Based on the data collected, B&C highlighted in the report a number of trends that companies involved in the manufacturing and importing of chemical substances subject to TSCA may find compelling. The report is available online: B&C Analyzes CDR Enforcement Actions from 2007 to 2014.