The Backstory
As you’re probably well-aware by now, under the TSCA Inventory Reset Rule, EPA must now designate chemical substances as either “active” or “inactive,” based on whether a chemical substance was manufactured/imported/processed during a ten-year window from 2006-2016; those manufactured, for example, prior to this, but not since, would be deemed “inactive.” The deadline to report chemical substance status to EPA was February 7, 2018.
What’s changing
Not only is the TSCA Inventory itself changing—from a single inventory to one that is partitioned between active and inactive substances—but so will documents that reference these data, such as Safety Data Sheets.
Implications
Users of Safety Data Sheets (SDS) often rely on the regulatory information of Section 15 to determine the “free-for-sale” status of a chemical substance, and ultimately the product containing that substance; substances not listed on the EPA TSCA Inventory are not “free-for-sale” in the US, that is, they cannot be placed on the market, whether through manufacturing, importation or processing/formulating— unless exempted by TSCA. Although OSHA makes the information in Section 15 optional, it has become standard practice to include “inventory” status in this section. Given that there are now two separate TSCA inventories, it will likely no longer suffice to simply state “US TSCA Inventory – listed” in Section 15 of the SDS. Instead, manufacturers, importers, etc., will now likely need to differentiate between whether a substance is on the “active” or “inactive” inventory, else be prepared for myriad questions from downstream users.
With automated software-driven solutions, such as that offered by Global Safety Management, these changes can be made with the click of a button—greatly reducing the implementation effort, saving you time and money, while providing your users with the most accurate information available.
