Wednesday, May 11, 2011

EPA Suspends the Submission Period for the Long-Awaited Inventory Update Rule (IUR)

Following many months of uncertainty, and with the deadline for industry submission approaching, the USEPA has issued a Federal Register Notice "amending the Toxic Substances Control Act (TSCA) Inventory Update Reporting (IUR) regulations by suspending the current June 1, 2011, through September 30, 2011, submission period for 2011 reports."  This action was necessitated because EPA till hasn't managed to finalize the IUR modifications rule that they have been working on since last year.

A revised submission period will be announced when the IUR modifications rule is finalized "in the next several weeks."  Once the rule is finalized EPA is promising that companies will have "sufficient time to comply with the updated IUR reporting requirements."  It represents a "one-time" suspension only, and the next scheduled reporting period is expected to be unchanged, i.e., June 1 to September 30, 2016.

According to EPA, "the suspension is warranted, EPA adds, "because it gives affected parties additional time to adjust their behavior in response to other portions of the proposed rule ... and because it averts potential confusion and duplication of effort, which could occur if other portions of the proposed rule, substantively affecting the submission requirements of the IUR, become effective in the midst of the IUR submission itself."

The Notice can be downloaded at:

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