Wednesday, November 29, 2023
12:00 PM - 1:00 PM MT
The Toxic Substances Control Act (TSCA) has seen significant activity in 2023, introducing new regulations, reporting requirements, and compliance challenges for manufacturers, importers, and other stakeholders. Our speaker gave a concise synopsis of key TSCA 2023 developments, 2024 CDR requirements, and the new PFAS reporting rule.
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VIDEO TRANSCRIPT
This transcript was auto-generated by the webinar. Please forgive typos.
0:03
Hello. My name is Amy, and I'd like to welcome you to today's webinar, Try hydro's tasker Compliance Update. What You Need to Know for 2023 and Beyond our speaker today is Andrew Pawlisz.
0:17
He will be providing information on that changes within tosca Reporting, as well as discussing the task of development, an update that 2024 CDR requirement and the new P fast reporting where all very excited to get started today. But I'd like to cover some housekeeping items first. First of all, all attendees are in listen only mode. If you have questions at any point during our time together today, please use the questions tab in your goto Webinar Attendee panel. We'll save a few minutes at the end of our session today for a Q&A with our speaker, Andrew. If we don't get to your questions during our time together, we'll answer them directly via e-mail after the webinar.
1:04
This webinar is being recorded. The recording will be available after the webinar, and we will e-mail it to you within a week. Finally, you'll have an opportunity to complete a survey after the webinar is done, and what only, it will only take you just a few minutes. And if he could take time to fill it out, areas pants is help us create valuable webinar experiences for you in the future.
1:29
And with that, I'll introduce our speaker today.
1:33
Andrew is a Board Certified Regulatory Toxicologist and Tulsa, Oklahoma. He specializes in developing and implementing risk based strategies for contaminated site assessment and closure. He also keeps tabs on environmental regulations impacting industry, including rulemaking activities for contaminants of Emerging Concern, such as P fast, and outside work.
2:00
He enjoys Saling, reading, obscure sci-fi books, and fixing vintage machinery. Andrew, I'll turn it over to you.
2:11
Thank you, Thank you Amy, and welcome to all of you to our comprehensive koska updates webinar.
2:23
And the object is for our kids to get it today are shown on the screen, but from very, very high level perspective, as I go through the general aspects as well as detailed findings on the latest and greatest I think we would like to start with little refresher on Tesco, particularly that it applies two industrial substance's compliance.
2:58
The second overarching theme would indeed, to share with you all the latest, specifically 2023 is activities under this rule.
3:13
And finally from the practical perspective.
3:17
I'd like to help you with getting ready for the upcoming test reporting and not just under CJR.
3:28
Because we're going to be talking about two final rules or P fast enough best us which have separate independent reporting requirements.
3:39
In details we provide a flex like Amy.
3:47
Next slide after that.
3:49
Thank you.
3:50
So when we think about Tesco, just just recall that this is the principle rule, four industrial chemical safety in US and the main intent of the rule is to identify and they can control any unreasonable risks lean so by EPA.
4:20
So, if you can remember that principal primary objective, and now I'll help you to understand all the activities behind this rule in the past and recently, next slide, please.
4:37
Also, I would like to point out that between its inception in 19 76, then significant reform in two thousand sixteen's, a lot has changed.
4:50
And this rule, refresher, has significantly wider the rise of influence, but also, the activity's under it, much different than they ever were under the formal room.
5:08
And looking at the present statistics, there are nearly 87 or maybe even now over 87,000 industrial chemical hooks, Sumer chemicals, on the inventory.
5:24
And also, another aspect to remember is that this rule is not expected to slow down anytime, Certainly not in 20 24. Next slide.
5:38
There are multiple environmental compliance rules in the US.
5:44
So, and there's a division between them.
5:48
So while through drys cosmetics pesticides are handled by FDA or paper or other rules, all the rest, all the other industrial sent, chemical substances tend to fall under tusk.
6:03
So it's almost like a catch all Brule regulations.
6:09
And one aspect also to remember, it's worth the reform task the agency.
6:17
And some of these aspects will be shown in the discussions on, for example, pathos and Best Festus agency.
6:29
Under the New Chemicals Review.
6:32
It's implementing the zero risk tolerance and more for those substances that need to review by EPA.
6:42
And then, as I mentioned before, 20 24 definitely will be continued implementation enhancement of our past programs.
6:54
Next slide.
6:57
When we talk about the task of the global inventory, there are two flavors within it.
7:03
And that's important because there is a distinction between the inactive substances and frequently they come with the legacy or the grandfather task inventory.
7:18
And then now, that designation also includes active compounds, And this split is about even looking up the latest statistics, one item to keep in mind from the compliance perspective with this.
7:35
While active, designated, active chemicals are allowed in a US commerce.
7:44
Those that are deemed are identified as inactive of inventory.
7:49
There will require form B or 90 day activation notice before commercial activity can proceed.
7:58
So that's another nuance of compliance with ..., from the general perspective. Next slide, maybe.
8:08
Then before we get into the specific updates of the final rules, and then subsequently provide the CEO refresher, reporting refresher, and other mechanisms got, I think anyone, practice your test should remember is this reform Pascoe staging process.
8:33
And those are demonstrated on the inserted graphic.
8:39
And the objective of the reform task is to take the form or the old inventory With the new chemical assessments that are coming in on regular basis.
8:52
And then end up with a safer inventory according to EPA.
8:58
And one more focus. I am, next slide.
9:02
It's just to look at closer, but the third stage in this process, and that's stage three.
9:10
That's the evaluation stage, Within it.
9:13
We have seven steps, and this will actually provide barings us to the 20 23 activity summary.
9:24
I will focus on section two of this webinar. So, Amy, next slide, please.
9:34
Next slide.
9:37
All right.
9:37
So, I have divided the various 2023 activities in this just main four stages.
9:50
Now, the reform taskers operating under under stage one reset.
9:57
There were none.
9:59
In fact, the reset rule was completed in October 2018.
10:07
Those who had commercial activity around that time are required to designate active inactive substances.
10:15
And that task has been completed and, at this time, the recent rule, as we call it, is dormant.
10:25
Yet, EPA, I believe, has the Ability two reactivating at some point down the road, but we don't see it happening Next year under the Stage two prioritization and this concerns the 22,016 original high priority subsisted designees.
10:52
We have activity for about seven out of the 20, and I'm not going to go through each and every line.
11:00
But essentially, ease encompass a combination of flame retardant solvents.
11:07
Some of them are chlorinated solvents, and then, there was a mineral asbestos and under the other statutory designation of low priority substances.
11:19
That was the not the other 20 that EPA has to keep.
11:24
On on the docket, there was no activities to see. Next slide, please.
11:31
So this is where it gets, gets a little more detail now, because now we're looking at activities under the, the Stage three evaluation, and those are listed here.
11:44
We have a test orders for PFS in plastics.
11:50
Hmm, Then Asbestos, I'm going to talk about the asbestos rule later on.
12:00
Do you want for dioxane?
12:04
Experience, revise, risk, evaluation.
12:08
And then next words, it's interesting because that foreshadows, what EPA's thoughts are on conducting risk evaluations.
12:19
So typically, EPA conducts revaluation, some chemical by chemical basis.
12:25
And then any adverse effects and impacts are viewed individually according to the chemical.
12:33
But now, we're looking at the cumulative risk assessment proposed approach.
12:39
And granted, this is this is for phthalates, but I believe EPA may want to try this for chemicals may be even PFS, which typically operate as a civics teacher.
12:54
Another aspect of interest is that, yes, there is greater interest in ...
13:01
in general and now EPA is looking at a new PFS risk evaluation framework.
13:09
And finally, this is not a news development but the new approach methodologies for reduction of vertebrate animal testing is still very much promotive by the EPA.
13:25
Next slide, please.
13:29
And, in this stage, this is, this is the final stage in the overall EPA's evaluation cycle, and this is where the newborn's regulations take shape, and they are proposed, or panelization, or, or revisions.
13:48
So, under the subsection is the proposed and final.
13:52
You can see the items listed.
13:56
and under the proposed section, we have the proposed prohibitions for kreisel light asbestos, methylene, chloride, tetra, ethylene, and track her ethylene.
14:12
Uh, another interesting development is that picture you recall, from the earlier slide, parties have the 90 day notice period for activation of inactive compound's.
14:27
Well, EPA is proposing that they would block that reactivation specifically of pathos without a new risk evaluation.
14:41
So, you can see there's tightening of that interest and pathos, though.
14:46
Um, and another theme that will be clearly apparent in the final ...
14:53
reporting, rule four, and then as best as reporting, or as well, is the the removal exemptions.
15:02
In this case, this is, uh, removal of the low volume exposure exemptions for PBDEs and PFS.
15:12
But as I will outline next section, there's additional exemptions that are no longer available that traditionally where.
15:23
And then switching quickly to define all in the interest of keeping moving, we have quite a bit of material to focus on today.
15:33
There's that known CVS Health Safety Data Dissemination, Electric Tools force via submittal, indication, three P a and then the last two items I will cover in detail.
15:48
So with this, that's the, That's the update on 20 23 activities under tusk.
15:56
So let's switch to the next section if you want to click through one month, right?
16:05
And, and this is a very, very, very interesting rule.
16:10
A lot of the telescoped practitioners experts had a lot of thought about how EPA is going about it.
16:21
But, I'll make you should make your own judgement as we go through some of these components, here.
16:27
Now, I will not go into any details on PFS themselves, hadden that indicate that this group of Florida compounds, by the way, used for decades, in industry and consumer goods, are now subject to increased regulations on the State and Federal level.
16:49
And this is mainly due to realization of the persistence by accumulation properties, some of the longer chain compounds.
16:58
And also, allegedly toxic properties.
17:02
So, EPA has a lot of activity devoted too PFS, not just under tesco's, no numerous numerous environments or rooms.
17:15
So, a quick overview of the final rule.
17:19
It is a new reporting burden.
17:22
I think this is for the first time that, um, BPAs looking at such comprehensive reporting, a PFS, dating all the way back to January 2011.
17:39
So it's a very, very long look back period, in my regulation section, added in the CDR which, which goes back four years. So it's a four year quadrennial cycle.
17:53
I did not recall the agency requesting such a long look back period.
17:59
It has complications.
18:02
For example, some of the archiving rules are inconsistent with this look back period, but EPA forks don't, nevertheless.
18:12
Another aspect that's extremely interesting is that, because of the complexities and that group size of pathos, EPA would like to look at it at least 1500 individual PFS species.
18:29
Then, the associated uses, so the breadth and scope of data requests is tremendous.
18:38
Yeah.
18:39
There a constant consequence of this rule also is that alike parties that are familiar with CR reporting every four years, under this rule, there will be partys, not previews to see your reporting or any kinds of reporting may need to report under the PFS Reporting Rule or PV p.f.r..
19:07
And similar to the CDX, there will be central data exchange with CDX portal to submit their information 20, 25.
19:18
And now, I'll provide the deadlines all of you later on.
19:25
So in terms of the affected entities, yes, We have the standard commercial manufacturers, importers and that it goes down on the current performer.
19:36
So if you had manufactured or imported, one of the 1500 PFAS compounds in the last 1, 10, 11 years, you are subject to reporting.
19:51
Now, this also entails an import as of now municipal solid waste.
19:58
Now, the municipal soil waste law rule, on the other hand, is exempt, and there's added entities, and here are the NAICS codes listed.
20:09
But I think one has to be careful whether or not they're subject to this rule.
20:17
And one final aspect on this slide is that if the PFAS compounds within that 1500 number scope has already been imported or otherwise, no handled previously, then there is no obligation for reporting.
20:39
Next slide. So, this is getting a little more detail now.
20:45
So here's the information that TPA is asking for. Somewhat familiar to what Sylvia or Torques are asking for.
20:55
The chemical identity molecular structure, which for some PFS, may be challenging categories of fears.
21:05
The quantities produce of each substance or mixture.
21:11
Then and description of bioproducts disposal information.
21:21
Then, any information on adverse impacts, human health, and environment.
21:27
The number of individuals, frequently, workers, exposed, and so in such.
21:33
So it's not surprising the amount of information, are the type of information that EPA is asking for.
21:44
Now, one thing to remember is that there's two types of reporting forms.
21:53
But then each form is for each reportable PFS.
21:58
So that could be quite a few forms, or mixtures, four articles, as well.
22:04
That's another you develop and aspects and distros that now Articles, a subject to reporting.
22:13
If the PFS are known to be contained there, then each site Greystone Reports and less, in Florida.
22:21
In that case, next slide, Amy.
22:24
That's the, usually the highest order of corporate organization that's listed EPA. Next slide, please.
22:33
Oh, I'm sorry, Not so fast.
22:37
I think this is a bit of a consternation to the experts.
22:41
Is that EPA's asking or a universe of up to 1500 chemicals?
22:48
Yet the agency's not providing comprehensive discrete lists of these compounds.
22:57
They do provide a chemical structure formula.
23:01
There's three of them but really, there isn't no specificity.
23:08
And I believe the guide is documentation syndicating that the users may refer two comp talk, talks dashboard or appendix C of the reporting instructions.
23:21
And then I gave the document there, but again, it's not an exhaustive, comprehensive cavalia.
23:30
So, ultimately, each potentially impacted party has to look at their ...
23:35
inventory and determine peer for public ability which which is quite challenging especially for those not accustomed, to Tesco.
23:49
Not accustomed to test curve 40, not familiar with the very complex B plus chemistry and such.
23:55
So, it is a total challenge.
23:58
Next slide.
24:01
So, talking about the challenges.
24:04
I didn't mentioned before that he pays trending in terms of removing the standard task type exemptions.
24:12
So in the past, typically, small businesses were exempt.
24:16
Got an exemption that's the one are available with the ....
24:21
In the past, also, andrus choose importers who are not required to report if there was certainly one quantitative thresholds meant.
24:32
For example, in CDR, it's £25,000 per year.
24:36
In this case, there's no exemptions for that.
24:41
No exemptions for byproducts who purities known ISO intermediaries, Palomas Mixtures, Commercial, Research and Development.
24:52
An imported articles testified all that will likely tail campus greater number of reports EES, next slide. It's really time to go.
25:07
So still second page of challenges, I mentioned before.
25:12
very, very large number of PFAS compounds.
25:15
Many of them have not been reported previously.
25:18
So there will be a tremendous challenge.
25:23
And EPA saying it narrow that, even if one is the position of environmental health.
25:33
And human health affects data, that might be subject to the reporting as well, even if this is January prior to January first, 2011.
25:42
So that's even outside the look back period.
25:47
And looking at some other aspects, it's a long, long list.
25:52
But, without a doubt, this man of detailed or requested information is rudder on precedent.
26:05
And for the value chain reporting, I do not believe the PFS are understood or even known to bein products, let alone tracked along the value chain before it gets into the US.
26:25
So, definitely, a deep thought, it will be required us to, how to obtain these data.
26:35
For EPA, next slide.
26:38
It's not necessarily doom and gloom, there's some mitigating factors, it is a one-time event, it fits this rule will be over width once the reports are submitted in 20 25.
26:54
There's the stream reporting availability or the articles, Hmm.
27:01
Commercial research development if the amount is less than 10 kilograms per year in that streamline reporting those optional deformation fields.
27:15
And then, if, if one is, does not know the exact amount of PFS in the articles, then just report the overall article, Mass Flow Counts.
27:29
And, I guess EPA will figure out the amount of P fasfa, maybe coming in or manufactured.
27:37
Now, duplicate reporting, those are big, many, many commentors indicated that we already are reporting.
27:46
This is foundation under different programs, for example, T T R I R, CDR in years past.
27:54
And it's not obligatory, however, when you look closer, had the amount of and extent of detail that the p.f.r.
28:04
is requiring and what was required in the past, with all exemptions, the overall overlap as men in law.
28:12
So in fact, the p.f.r.
28:13
is much more onerous, so mass flow report.
28:19
There's also some exemptions for non commercial research in development.
28:25
And importation, as I mentioned before, municipal solid waste or disposal destruction.
28:33
There's also exemption for non chemical substance under Tesco.
28:38
There's a definition there, and also even if PFS is found in, in in mixtures, dyadic components are not subject to reporting.
28:51
If parties choose so to do so because of CBI or other reasons, they may submit joint application submissions.
29:01
And if anything is confidential, there's that CVA, CBI of Ability.
29:09
Sorry, I also mentioned last time, just like any other Cosco Rule.
29:13
The recordkeeping requirements is five years.
29:18
And then the last bullet, actually extremely important.
29:22
Let's talk about it in the next slide.
29:28
So, this is a task: standing reporting standard.
29:33
So, in the first bullet you can see that quotation, nope now to or reasonably ascertainable by in persons, submitters, possession, control, or knowledge.
29:52
Now, the caveat is that EPA is indicating that, um, guess the manufacturer import or outer layer party would the reasonably search for the information, but not only within the organization's purview but also up and down this value chain, to fill that p.f.r. duty.
30:18
So, recommendation is that parties that are subject to this rule should fulfill the due diligence, searching, retrieving and requesting required information.
30:33
And by doing so, they will engage with the value chain partners, but it is very important to archive all these activities.
30:42
In the case of audit, Do you need to demonstrate to EPA auditor that you have performed your duty of due diligence?
30:52
So that and ..., it's available, but only after you do your best, so to speak, to retrieve the information the best you can.
31:06
So, there's a nuance to it, fine line, but that the core standard. Next slide.
31:16
All right, so, it comes to the burden parties, in fact, that, and the rule indicates certain NAICS codes.
31:27
However, however, under the second bullet, under 40 CFR 75, 10, and 12, additional activities and parties may be impacted.
31:43
So the recommendation is to look very, very carefully at that section and make a rule applicability determination.
31:52
And if you'd like, you can contact EPA.
31:55
There'll be willing to do so.
31:57
If you're not comfortable with getting AGC word on that, contact your favorite consultants and, or lead get legal advice, environmental lawyers, to ask for lawyers.
32:10
And they'll be able to help you out.
32:13
In the end, in the rule, and EPA went back and forth how many respondents are potentially impact by this rule. But you can see the number.
32:24
It's quite high in Nepal in terms of number of responders, but also the yearly annual million hours acquired to comply with this rule. Next slide.
32:40
I was trying to compare and contrast this rule with CDR.
32:44
And, in general, it's similar I think.
32:46
anybody who has completed undertaken CDR reporting, there'll be family oddity.
32:53
The one thing that will strike you, And I said, in many times, it's much, much more complicated, more involved.
33:02
And then the look back period.
33:04
Definitely.
33:06
We're already having difficulties retrieving information for years back?
33:12
They get it back beyond four years, looking for it, maybe even more difficult because, personally, changes, departments change, ownership of the company's change and archives, get purged or otherwise become inaccessible.
33:28
So no doubt.
33:30
It'd be more difficult to obtain information doubtfire back.
33:37
Alright.
33:37
And then, finally, the lack of availability of this exemptions definitely increases the scope compared to regular CDR.
33:48
All right. So, that's next slide. Amy is the final slide for this section three.
33:53
Are we going to move on to the next? We've been really good on time, Thank you.
33:57
So, here are the top three takeaways.
34:00
It's a brand new reporting rule with extended look back period for information solid, um, tremendous number of PFAS compounds known and lesser known compounds to report.
34:18
And if you dabbled with PFS, you could probably find cost numbers, but those compounds may be trade names, but others may not have Kass Numbers or they may be confidential.
34:33
So accession numbers will be needed or in some cases, they may be very informational, not off.
34:42
And then finally, on the, on the third item there, I think that, and I'm not sure how this may be communicated to the parties may need to report, but they don't realize that they need to.
34:58
There's going to be a greater number of business entities having to report, come into an attorney.
35:07
So, the rigor, the impact statement is right there, not going to say anything about that.
35:12
You can read it and Amy indicated you will retain a copy of this slide deck for your own use.
35:19
But one thing to keep in mind is that, um, failure to comply with the rule will be violation and subject to penalties.
35:32
I think that that occurs all the time.
35:36
And then finally, the reporting deadline for reference, there's two sets of deadline, large manufacturers importers, it's May 8, 2025.
35:47
And the small entities in there is a business side definition under 40 CFR 74.3.
35:56
They have little more time to report, but any end that's not that much time, because 20 23 is almost over.
36:06
And then 12 months next year you're gonna need each and every month to retain information.
36:15
Look for it, determine if it's subject to the rule, tried to figure out which PFS you have within your inventory articles, large enquires with your value chain members.
36:28
I'm sure there will be refusals or, um, folks will not respond right away.
36:34
So, that's not that much time.
36:37
And then, the first round is coming up May.
36:41
So, again, that's not that much time for this.
36:45
So, I guess the recommendation is to start extremely early.
36:49
At least start with the determination of whether or not your organization they need to fall under this one time reporting rule PSAPs. So, thank you, Amy. This is, this is end of section three. Now, we're going to move to Section four.
37:08
And that's Section 406. So you're doing really good on the overall progress here.
37:13
And we may have time for questions. If we don't, please e-mail them, or put them in the chat window.
37:21
And I guarantee you, we will respond to each and every enquired that you may have.
37:27
As a result of this presentation later on, as you kind of digest and think about these rules, say, you know what, I have a question. You have my have configuration.
37:38
Call me, or text me, or e-mail me anytime you'd like.
37:44
All right.
37:45
So, this is the second final rule that was published this year.
37:51
Again, this is another one of those one-time reporting rules.
37:55
So, it seems that it seems to be developing a pattern of GPA that EPA seems to be information hungry.
38:04
Um.
38:06
And what's interesting about this rule, this may be different from in some way, from the PFS one time reporting rule is that not only manufacturers importers but also EPA is calling out the processes processors.
38:25
So, that's one more aspect of the activity that's very much called our Hamlet, this room.
38:37
And they do have A revenue limit.
38:43
For those entities, which is a type of exemption, according to the business size.
38:51
And that's positive.
38:54
And then, in terms of the data requested, that's pretty well standard with what we see on the CDR.
39:03
So, that concerns, the quantities produced, processed, types of use, worker and exposure information. And you can see that the look back period does in 9222.
39:18
That's a narrative, quite reasonable, period.
39:23
And the next bullet, Syndicating none else, not only as Best containing products articles, but also those that include natural substances, and then impurities and including us mixtures.
39:41
There are more exemptions available under the asbestos rule compared to ..., but still, there's a trend of reducing of the standard tasker exemptions here as well.
39:55
The entire Array Reporting Standard applies.
40:00
And CBI claims are available as one.
40:04
And just about anything else with EPA these days, um, reports will be due 9 May 2024.
40:16
We are CDX and there'll be two separate forms available.
40:21
Well, the responder send, the next slide gives you a little bit overview of all what form A will look like, and that form is to be used by small manufacturers, importers, processors, of specific type of group of asbestos compounds, And that's called de Libby, Amphibole, asbestos, So only got type of asbestos.
40:48
The grouping off can use that, Reduce Form A, if you're our research and developer, it's called quantities, you may use that form.
41:01
And also, if you happen to come across the non isolated intermediaries aspect.
41:12
And another aspect of utility of that form is God if you don't have the full extent of the data requirements that are subject to formby.
41:26
So as best is when it's manufacturers' imported processed, you may use this form as well.
41:35
Let's look at their form B Amy. Next slide.
41:41
So this is the standard form, and this is for the large manufacturer ...
41:46
processors, and this is for any form of semesters Even lidia, and then you have full information available to report to EPA.
42:02
Next slide, we've done a little quicker.
42:05
We get to the Section five.
42:10
Here are the asbestos types listed under the rules.
42:15
So there's the general cast number, and there's six specific cost numbers.
42:21
And then, as indicated in the affable, is composed of three other cast number of semesters from. Next. Slide clicker.
42:33
Now, here's the information that's requested, fairly reasonable.
42:41
I think it's a long, long list, compare it to some of the other requirements elsewhere.
42:47
But I think that decision relation should be available to most entities.
42:55
Next slide, Amy.
42:58
In terms of the top three takeaways, again, we're looking at one time reporting rule.
43:04
This time, a little bit more compact look back period.
43:10
Typically, all asbestos forms are subject to reporting except liddy, comfortable.
43:16
And this is very much looking like CDR.
43:21
there are cries.
43:23
Then there's the deadline for you to keep track of who's just on the phone.
43:28
It's not that much time at all coming up in May 24.
43:34
All right, Amy, let's focus on the loss.
43:39
Larger section. We have about 15 minutes remaining.
43:43
Next slide, and this is a quick refresher your standard standard CDR reporting that's performed quadrennial.
43:53
I'll go through rather quickly, number one, and maybe already information people are familiar with.
44:00
I'm just going to stop, is going down.
44:03
Some of the important aspects, if it's new a little bit, compare and contrast with those one-time reporting rules, but in the end, ..., go through this section fairly quickly.
44:15
And, again, you have set up the slides for your own use.
44:20
So, we're looking at next reporting cycle.
44:25
EPA has issued Federal Register notice.
44:28
Now, officially, the reporting period is from June first, are four through September 30th, 2024.
44:37
And that was subject to years 220, 221 to 23 calendar years.
44:45
And if you did this last time, last reporting was 20 20, and it covered the other four years back.
44:54
So in this case, this is standard traditional approach. We'll talk about threshold exemptions.
45:01
So £25,000, typically, that's the annual production.
45:06
For each chemical, subject to potential reporting.
45:11
And then we're looking at both manufacturing and importing this one and the same under Costco for commercial purposes.
45:22
And also, keep in mind, that each facility, each production facility, has to report, but for him, Florida, as I mentioned before, is the highest corporate organization level puts their name down on the report.
45:40
Now, what's new, like the last reporting cycle of 202020, which these OECD codes were optional, now they become mandatory.
45:51
So that's one major change from the last report. Next slide.
45:58
Alright, so here's clicks to experiment which cameras to consider: individual compounds, pull compounds, with specific cast names, numbers, UVC be subject to reporting, mixtures ALIS solutions.
46:15
What's excluded?
46:17
And I mentioned before, there's other rules that control otherwise regulate food drugs, medical devices, cosmetics, So they are not subject to the next slide.
46:30
Exemptions, and here's a full list of what typically we see, ..., practitioners, exemptions.
46:38
Suppose this micro-organism certainly listed forms natural gas, known ISO intermediates, intermediates, they're exempt.
46:48
But in the previous one time reporting rule, under four P plus it's not byproducts.
46:55
Exempt impurity is exempt R&D substance's exam and then, if they imported the cost part of an article they exempt, yet, under ... reporting rule, they're not exempt.
47:09
It can be quite confusing need to pay attention. which rule are you talking about?
47:15
And then spy manufacturers were exams, are exam, CDR yet under the PFS reporting rules are known OK, So next slide, Here's some partial exemption. So what it means that you don't have to report all the required information, just some of it.
47:37
And then you have those two types of compounds.
47:43
A group of compounds listed that had only partial reporting requirements, excellent.
47:54
All right, so if you're going to prepare Series database first side, this is the information you're going to need.
48:02
I mentioned the threshold exemptions.
48:06
And also, we have the concept of the principal year for which extra extra inflammations, personal use information is required.
48:15
So, this year will be turned 23, that's the principal years, and then that standard, right? And ... standards.
48:25
So, that also applies here. So what is now no reasonable ascertain information.
48:33
And then PVI also is available, next slide.
48:39
In terms of the processing data, here's the list, I'm sure this is very familiar to most of you.
48:48
I'm not going to go too much detail on that, And that those are the data elements required. Next slide, in terms of the users.
48:59
So we're looking at the top of users, sectors that use for that use, then we look at the production volume for each type of use, number of sites, and so on and so on.
49:14
So, go ahead and next slide. Just go through quickly.
49:19
We're going to be submitting the form you, although, we haven't see actual for me a long time, although you will see that if you print your, see our report.
49:30
I'm CDX, and, the C D R C D X Reporting Tool, if I can call it that.
49:40
It's quite friendly.
49:42
I know last time when we did this, and 2220, that the reporting tool was being rolled out of those beta testing and I think EPA is going to have another benefit, a testing, exercise for the updated reporting.
49:54
Cool, that is straightforward.
49:56
It's interactive, was very nice. Pull down menus.
50:00
You can search for cast cast name, cast's numbers and such.
50:05
And also, because it's all electronic, you can have multiple individuals involved.
50:09
You can have your agent, the consultant, you can have your organization designees enter their information.
50:17
But only the print, the primary purpose official may certify and submit the report final, spinal TPA.
50:28
Next slide, real quickly, all right.
50:33
So, like with any of this, talking about the ...
50:38
reporting role, certainly the asbestos reporting world and now CDR because there's so much data requirement.
50:48
And also, you need the archives, and you need volumes, information, uses workers, and search.
50:54
Start early.
50:56
We can never stress the fact that folks may be thinking, Oh, it's you know, we're four years or I still have to 20 25 to think about it for now, because there's a lot of delays in getting information to you.
51:10
So we can never overemphasize the importance of starting the City of Surrey.
51:21
And because of that, there's the multi stakeholder effort acquired, need to get with your procurement, your process engineers, your marketing folks, R&E and legal as well.
51:36
So, definitely a lot of time and effort being put in.
51:41
It's also important to QA QC, your data before they entered into the CDX.
51:51
And then also keep in mind I mentioned this that or the next reporting cycle.
51:57
EPA is looking to update the Chemical data reporting Guidance Fernando Woodcuts Reporting Tool and that hasn't been now so I checked it this morning as we know announcements from, yes.
52:14
Next slide, Just a couple of slides, slide one slide slide.
52:19
Is that the necessity two, Keep in mind that agencies performing audits.
52:29
Therefore the recordkeeping is extremely important.
52:33
So just about any scrap information could help you in terms of responding to an audit requests.
52:44
And then as I mentioned before, by the rule, you need to keep your archives records backups, at least five years.
52:53
Not sure what your owns institution, its position or organization, records keeping attention, policy is, but hopefully it entails the five years to test her acquires.
53:10
Now, in terms of typical pitfalls in reporting or audit findings, it's under reporting.
53:21
Mainly because you don't may not have the information or you're not aware.
53:27
The information is reportable.
53:30
Or, you do think that, Maybe you know it's OK not to report everything.
53:35
Well, I think the advice I would have to any of my clients, and they do, is the Maoists want to read over report.
53:44
There is no penalty necessarily for over reporting to EPA on Tosca, but certainly there's complications if you do not report something that EPA would be more supportive.
53:57
So, it's better to provide more information than less.
54:02
Uh, there's also the challenges with the chemical Nomenklatura issues.
54:10
Know, is this the cast number I'm supposed to be using, or this is the chemical name is supposed to be using?
54:17
I thought that was OK. But in the end, it has to be just the right chemical name that EPA will accept.
54:24
And I think the see our reporting tool the online version now will help you because he can search the SRS database directly.
54:34
But the right culture, and then Recordkeeping, I think that's that's something that can be managed within the institution.
54:45
So with this, Amy, I think this is the the end of Section five, CDR refresher.
54:53
And now we have about five minutes left, left, four, just a retrospective summary.
55:03
But let's go now, so next slide. So here's the sunlight.
55:07
OK, so the taskar Rule Program, whichever you want to call it, this, is quite active under the 2016 reform role.
55:19
And I don't think that that's going to slow down any time.
55:24
It has been, and will be, the Industrial Chemical workhorse for EPA.
55:31
And that's actually increasingly used to assess existing and certainly regulate the priority chemicals that you recall from the first section.
55:42
We have the 20 high priority substances, circa 2016 designation, and then you have the 20 low priority substances.
55:53
So, there's definitely, uh, a lot of activity within that.
55:59
And also recall that a lot of these 20 H P S S are nearing completion.
56:08
So, they entering that last Stage four cycle.
56:13
And then EPA will be picking additional compounds to replace those, because by Statured, they have to have 20 popularity and 20 low priority subsidies on the docket attend.
56:28
And as you can, maybe appreciator of the subways are provided for the one time reporting rule.
56:36
And this is not the only environmental program, though, we see this, is that EPA has heightened focus substances that the H C gene sets unsafe.
56:48
And now, with the elimination of the exemptions.
56:53
Now, we have byproducts and impurities being incorporated into the report as well.
57:01
That reporting would be used by EPA, to assess, and you management, and you risk management, requirements down the road.
57:12
And because of those longtime reporting rules, in addition to the existing rules that we have on the PRI, or healthcare or others and CDR, we can see that the agency has increased an appetite for information.
57:26
That's very, very apparent.
57:29
And unlike previous reporting, which the smaller business entities, we're not asked to participate now.
57:38
We've seen those small entities also being a party to the roots.
57:45
Then the last two bullets, I like to leave the audience with is that, let's not wait own in terms of making way for the 2020 or CD Rs.
57:59
And the one times column, one times a day reporting rules for ..., especially asbestos.
58:08
And also being on the lookout for any updates EPA's indicated in their federal registered, which was published in June that not only the announcing the formal reporting window for CDR, there also indicated there'll be updating some guidance and also be updating the reporting tool in CVS. So with this, I believe we have two minutes left.
58:38
If if anyone has any questions, I'll be prepared to entertain those or a minute or two minutes or so.
58:51
Thank you, Andrew. We did have a couple questions come through.
58:57
Question can, I think I'll start out with one of those questions. And, like we mentioned before, if we don't get to your questions and our time together today, we'd be happy to answer them over e-mail after the webinar is complete. What is the reporting requirement for a facility that only has key fast containing a triple F stage for disposal?
59:30
OK, if he may repeat the question, sir facility.
59:35
Yes.
59:37
Yeah, so, what is the reporting requirement for a facility that only has PFS containing a triple stage for disposal?
59:49
I don't I do not believe that there will be any requirements for that, because, if you think about tosca, task is concerned with manufacturing, so, essentially, generating a new chemical compound.
1:00:04
And, in this case, it seems to facility, is not de facto, creating any new.
1:00:14
PFAS compounds are even byproducts, they're off, or impurities.
1:00:19
So I believe there will be no tasker requirements.
1:00:24
However, if you'd like me to dig a little deeper and provide you with the rules citations, please give me your contact information and I can reply with the formal assessment of that question.
1:00:39
That sounds great, We have a couple other questions, but we approached our time together at one o'clock on the dot, so, in respect to other people's time and busy schedules, I think we'll go ahead and wrap it up again.
1:00:56
We will answer these questions that were submitted over e-mail after the webinars over. If you have additional questions, please be sure to fill out our exit survey. There's an opportunity to, in the survey, to request some one-on-one time together to discuss your interests further. Also, are recording of today's webinar will be delivered to your inbox over the next week. And if you'd like to more learn more about try Hydro, please feel free to visit us on try hydro dot com. Andrew's contact information is on your screen right now. Feel free to reach out to him individually. He'd be happy to answer any questions or fill you in on some additional information that wasn't covered today with regards to task. Of course, he covered at all, it seemed like in great detail. But thank you again for joining us today. We hope you all have a safe and wonderful afternoon.
1:01:56
Text, second one. Thank you.