Staying Compliant: Toxic Substance Inventory
The EPA’s Toxic Substances Control Act will require some specific reporting later this year. Will you be prepared? Even if you are exempt from other types of EPA reporting, you could still be affected.
Industry Week’s James Votaw writes, “Beginning in the third quarter of 2017, companies of all sizes and in nearly all industries will have 180 days to investigate, identify and report to the EPA each chemical substance that it has manufactured or imported in the past ten years, regardless of the amount.”
This measure is an effort to bring the EPA’s list of chemicals up to date. For businesses who have had a number of different operations in various locations over the past ten years, it is recommended they start compiling these records now. This process will be less taxing for businesses who have had a limited number of operations, and have been in existence fewer than ten years.
Votaw notes that during this process, manufacturers distributors may discover lapses in compliance with previous or currently existing regulations. He suggests requesting a voluntary audit from the EPA. “Under the EPA’s audit policy,” he advises, “the audit would give companies the opportunity to promptly disclose and correct any violations discovered without incurring gravity-based penalties.”
To read more, see Votaw’s full article from Industry Week.