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On March 14, 2017, IPC filed comments on the EPA’s proposed regulations to “reset” the inventory by sorting the TSCA inventory into active and inactive chemicals. The inventory reset is one of the implementing regulations under the “Frank R. Lautenberg Chemical Safety for the 21st Century Act” (LCSA) which amends the Toxic Substances Control Act (TSCA).
IPC’s comments support EPA’s proposal to have chemical manufacturers, who have the primary responsibility, to report first, followed by a voluntary period for processors to report substances that have not been placed on the preliminary active list by EPA or manufacturers.
IPC also encourages the EPA to limit the rulemaking to collecting data elements that are required by statute, clarify the definition of “processors,” and clarify the exclusion of reporting of chemicals in articles.