EEC provides support to international clients for the complex and time-consuming tasks associated with regulatory compliance with the Toxic Substances Control Act (TSCA). Outsourcing this process to EEC’s team of actively involved, engaged and experienced regulatory professionals on a daily basis has proven to be a highly efficient and effective way to address the challenges associated with chemical control laws. Services are provided on a discrete project task basis or on a scheduled, as-needed basis; ranging from fully outsourced TSCA compliance to project-based, function-specific areas. EEC’s team of TSCA Compliance professionals performs the following tasks:
- Regulatory Tracking – Monitor EPA activity, federal register notices, final rules, enforcement activities, direct compliance measures and TSCA reform
- Spearhead TSCA Compliance – Interface with your management team, regulatory personnel, and others to direct and/or develop your TSCA compliance program
- TSCA Section 5 – New Chemical Substance Compliance Support, Pre-manufacture Notice (PMN) requirements, Low Volume Exemption (LVE), Notice of Commencement (NOC), Bona Fide Intent to Manufacture (BFIM) requests, Polymer Exemptions, etc.
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- Consulting with client
- Consulting with EPA – Pre-Notice Communications (PNC)
- Review of test data and other supporting documentation
- Collaboration with customer chemists and regulatory personnel, industrial hygienists and other professionals
- Preparation of notifications through ePMN/CDX PMN, LVE, BFIM, SNUN, NOC
- Act as Technical Contact during review and serve as Technical Contact on submissions to EPA
- Chemical Data Reporting (CDR)
- Review inventory update report requirements for current reporting period
- Prepare Form U for submission using eCDR
- Review current mechanisms for tracking volumes and other required information on imported and manufactured products and materials at substance level
- Complete report on electronic Form U for signature and submission
- TSCA 8b Inventory Status Reviews and Certifications