New Changes to TSCA – Blessing or Curse?

Congress passes bill to modernize nation’s primary chemical management law

The last time the U.S. Congress passed a major environmental law relating to chemicals, Gerald Ford was president, the Dow was around 1000 and Apple Computer was just a few months old.

Now, 40 years later, that law – the Toxic Substances Control Act (TSCA) — is finally getting a much-needed update. On June 7, the Senate passed changes to the TSCA, which the House of Representatives had already approved. President Obama is expected to sign the bill into law soon, making it the first major new environmental law since 1990. Bill Summary and Text

The new amendments will strengthen EPA’s authority to regulate new and existing chemicals and to restrict or ban chemicals already in use, and will likely increase the costs and time involved in introducing new chemicals into the marketplace.

So what will all this mean for companies that manufacture, import or handle chemicals?  Here are a few key strategies that may apply to your business:

  • Prepare to “defend” chemicals already in use. The amendments open the door for EPA to reassess existing substances that could pose a potential safety risk. The burden of proof as to what’s safe also shifts somewhat to the manufacturer or importer, with the new amendments empowering the EPA to require manufacturers or importers to perform testing of any chemicals deemed potentially unsafe. If your facility manufactures, imports, or processes a chemical that the EPA could determine “may present an unreasonable risk of injury to health or to the environment,” it’s important to be proactive. Familiarize your team with the new law and be prepared to either develop the needed safety information or to find alternative chemicals to use instead.
  • Plan on longer lead times and more costs when introducing new chemicals. Under the current law, companies must submit a pre-manufacture notification (PMN) to the EPA at least 90 days in advance before manufacturing or importing a new chemical, but there’s no requirement for the EPA to make an affirmative safety determination. With the new amendments, EPA must review AND approve each PMN. That will likely place a heavy administrative burden on the EPA, and there’s no firm deadline as to how long the EPA may take to respond. Also, expect the fees for filing a PMN to increase.  Currently they’re capped at $2,500, but could increase as much as tenfold.
  • Expect tighter scrutiny on Confidential Business Information (CBI) claims. Companies should develop strategies for making new CBI claims, as well as for reassessing past claims, which may need to be re-substantiated in light of the new amendments.

Finally, the amendments make significant changes to the penalty provisions of the TSCA, increasing the penalties and fines and adding a special criminal provision. It’s important work closely with environmental counsel to get “up to speed” to the new law and to develop strategies to ensure compliance for your company’s chemical manufacturing, importation and processing plans.

Thoughts – On its surface, these amendments seem like more government red tape for industry.  Yet, the revisions have been embraced by the American Chemical Council.  Feel free to comment.

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