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| Internal Auditing |
| SPC |
| Integrated Management Systems |
| Six Sigma |
| Root Cause Analysis/Problem Solving |
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 The Toxic Substances Control Act (TSCA) provides the United States Environmental Protection Agency (US EPA) with the ability to track the 75,000 industrial chemicals currently produced or imported into the USA. EPA screens these chemicals and can require reporting or testing of those that may pose an environmental or human health hazard. From this screening, the EPA can ban the manufacture or import of those chemicals that are thought to pose an unreasonable risk. The EPA also has mechanisms in place to track the thousands of new chemicals that industry develops each year. Under TSCA, each new chemical must be registered with the EPA before it can be made or sold for commercial use. That registration requires the submission of environmental, health and safety (EHS) information to enable review and approval. If the TSCA review concludes that the new chemical has either unknown or dangerous characteristics, the EPA can either reject the registration application or impose various restrictions on its use. What are my responsibilities under TSCA?
It is your responsibility to know if the chemicals used in your manufacturing or other applications (i.e. cleaning, etc.) are registered under TSCA. The supplier of your chemicals should provide appropriate notification in their product documentation, such as Material Safety Data Sheets (MSDS). If your process creates new chemical intermediates or by-products that will be sold, the TSCA registry should be checked to verify if they are listed. If there is no listing of that chemical, a Pre-Manufacturing Notice (PMN) must be submitted before commercial sale can commence. Penalties for non-compliance can be substantial ($25,000 or more per infraction depending on severity). Omni Tech's Training and Consulting Services
for TSCA
Consulting Services Omni Tech professionals experienced with the TSCA statute and regulations can assist your staff in understanding how these complex regulations apply and what procedures should be adopted to ensure compliance. Omni Tech can also audit your existing procedures for documentation and compliance with TSCA. In addition, if training or auditing is not warranted, Omni Tech can file PMNs on your behalf. Training Services. Omni Tech can also provide customized training on TSCA. Participants will learn how to prepare and submit PMNs under TSCA. Length of the session depends upon number of participants and depth of knowledge required.
For information
contact Jim Pollack at:
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