EPA Rejects House Republican Request to Extend CDR Submission Period


Source: EPA
Related Topics: Toxic Substances Control Act (TSCA) US Environmental Protection Agency

In a January 13 letter to EPA Administrator Lisa Jackson, Rep. Fred Upton (R-Mich.), chair of the House Energy and Commerce Committee, and Rep. John Shimkus (R-Ill.), chair of the Subcommittee on Environment and the Economy, requested that the CDR submission period of Feb. 1 – June 30, 2012 be suspended to align with the next CDR submission period — June 1 to Sept. 30, 2016.  The letter also asked the agency to address the following questions:

  • Must a manufacturer report on its entire byproduct stream or just on the amount sent for recycling? (EPA declined to answer, saying there was no internal consensus on the matter.)
  • Must a metal extracted from a byproduct be reported under the rule? (EPA declined to answer, saying any response would be “context specific.”)
  • Is double reporting required for extracted substances if sold as individual chemicals? (EPA said the proper agency official was not participating in the webinar.)
  • What is an exporter under the rule? (EPA said a response would require too much time.)
  • Is reporting required if the same chemical changes concentration?
  • Must a used solvent that is resold be reported?

In an EPA response letter it states that, “the current five month window for companies to report, along with their ability to engage the agency directly on any questions or issues they may have, provides an adequate opportunity for reporting by June 30, 2012.”  The agency did, however, respond to the questions that were in the letter.  For more information on the CDR, click here.

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