On Wednesday, September 25th, EPA issued an Advance Notice of Proposed Rulemaking (ANPR) that would require facilities that submit Toxic Release Inventory Form to include chemical use reporting information.   This information, also called materials accounting,  would require facilities to track the amount of chemicals that enter their facilities, the amount transformed into products and waste, and the amount that leaves the facility.  

Currently, TRI requires facilities to report that amount of chemicals that are treated on site or are shipped off-site for disposal, treatment, and/or recycling.  There is some concern among industry representatives that a materials accounting requirement is unauthorized by current law and may force them to disclose proprietary information to the public as well as competitors.  As a result, this proposed rulemaking is expected to generate some controversy.

Electronic copies of the ANPR can be obtained at http://www.epa.gov/opptintr/tri

Facilities can submit comments on the ANPR.   Comments should be sent to OPPT Docket, TSCA Document Receipt Office (7407), Environmental Protection Agency, Rm. E-G099, 401 M St., S.W., Washington, D.C. 

Comments may be submitted electronically via: [log in to unmask]

IPC plans to monitor the development of this rule and will be submitting comments on behalf of the industry.  I would welcome any insights that you could provide on the proposed rule.  Please e-mail comments to me at [log in to unmask]

Thanks

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