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Feature Article: Inventory Update Reporting

Posted on April 12, 2011 by James Griffin

Facilities that manufacture or import chemical substances should be preparing for the pentennial (once every five years) Inventory Update Reporting (IUR) requirements [40 CFR 710]. The Toxic Substances Control Act (TSCA) requires the EPA to maintain an inventory of every chemical substance manufactured or imported into the United States [TSCA §8(b)].
 
If your site manufactured or imported a chemical substance in a quantity greater than or equal to 25,000 pounds in the calendar year 2010, then your site will be subject to the IUR reporting [40 CFR 710.48]. Each facility meeting the threshold for any specific chemical substance must submit a detailed inventory update report between June 1 and September 30, 2011. A separate report is required for each chemical substance that has met the reporting threshold at that site.
 
The EPA uses the IUR data to support many health, safety, and environmental protection activities. The EPA explains that the IUR reporting is intended to collect exposure-related information on chemical substances and to make that information available for use by the EPA and, to the extent possible, to the public. The IUR data is used to support risk screening, assessment, priority setting and management activities, and constitute the most comprehensive source of basic screening-level, exposure-related information on chemicals available to the EPA. Additional information on domestic processing and use must be reported for chemicals manufactured in amounts of 300,000 pounds or more at a single site during 2010.
 
In the past, the information was to be submitted on a standardized report, Form U. During the previous report, for 2006, the EPA piloted an electronic reporting platform, e-IUR. On August 13, 2010, the EPA proposed modifications to the IUR reporting rules that would take effect for the 2010 report [75 FR 49656]. Included in the proposal was a requirement for electronic submission for all reporting facilities, using the Agency’s web-based reporting software and CDX reporting platform. While the Agency did have a training session in November, based on the August 13 proposal, they have yet to publish a final rule. In addition, certain members of the U.S. House of Representatives Committee on Energy and Commerce presented the EPA with a letter on April 4, 2011 urging a withdrawal of the proposed revisions to 40 CFR Part 710.
 
Whether the EPA mandates electronic reporting, covered facilities will still need to compile the manufacturing, processing, and use data for applicable chemicals and submit this IUR report this summer.