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December 06, 2013
More electronic reporting required under TSCA

Under a new rule effective March 4, 2014, chemical companies will be required to electronically report information required by the Toxic Substances Control Act (TSCA).  According to the Agency, electronic reporting enhances the accuracy of the submitted material and, after start-up expenses, reduces costs for both companies submitting the information and for the EPA at the receiving end.

The Agency says the rule will improve EPA’s management and leverage of information resources by reducing information collection burdens on the public; increasing EPA’s program efficiency and effectiveness; and improving the integrity, quality, and utility of information to all users within and outside the Agency, including capabilities for ensuring dissemination of public information, public access to federal information, and protections for privacy and security.

Four TSCA sections

The e-reporting requirement affects material submitted for the following TSCA sections:

  • Section 4, including test rules and enforceable consent agreements.
  • Section 5, all Section 5 notices and support documents.  In a January 6, 2010, rule, the EPA established a phase-in period for e-reporting of Section 5 information.  The current rule terminates the phase-in period. 
  • Section 8(a), preliminary assessment information.
  • Section 8(d), health and safety data.

CISS and e-PMN

For most of the required information, reporting entities must use EPA’s Chemical Information Submission System (CISS), a Web-based reporting tool.  The exception is for Section 5 data, which still must be submitted using EPA’s e-PMN software.  Regulated entities must go to EPA’s Central Data Exchange (CDX) website to report to the Agency. 

The EPA notes that the CISS tool employs a hands-on process in guiding users through the completion of an electronic submission.  Once a user inputs the relevant data fields, attaches appropriate PDF or other file types, and completes metadata information, the CISS tool validates the submission by performing a basic error check and ensuring that all the required fields have been filled in and all attachments provided.  The CISS tool also enables the user to submit confidential business information (CBI) in an electronic format.  The user must submit a sanitized non-CBI document as well as the CBI document. 

In addition, the final rule establishes the legal dependability of electronically submitted information by ensuring the application of a valid electronic signature that can be submitted into evidence, ensuring that electronic documents can be authenticated to provide evidence of what an individual submitted and/or attested to, and ensuring that electronic signatures resist repudiation by the signatory.


Users must register at the CDX website to use the system.  The EPA says it strongly encourages TSCA submitters to register with CDX in advance so that they are in a position to report when the need arises.

The EPA adds that it recognizes that there will be obstacles to overcome as submitters register at CDX and learn the CISS tool.  However, the EPA says it has received positive feedback from industry submitters that have been required since September 2011 to electronically submit chemical inventory information under TSCA Section 8(a).  Also, the Agency notes that the CDX system has been in operation for over 10 years, and, during that time, the EPA says it has continued to improve the registration process so that it is more efficient for users.

The final rule requiring electronic reporting under TSCA was published in the December 4, 2013, FR.

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