This gives companies an additional three months to continue to manufacture, import, and process substances, even though the substances are “identified” as “inactive” on the TSCA Inventory.
Back in February 2019, the EPA posted a revised TSCA Inventory on it’s website that listed more than 45,000 substances as inactive and held a webinar in March 2019 informing participants the 90-day transition period was underway with the designation of inactive substances becoming effective on May 20, 2019.
The EPA failed to issue a signed action when it posted the revised inventory in February, causing the May 2019 date to be invalid. Instead, EPA Administrator, Andrew Wheeler, signed a short memorandum that went out on May 6th which stated the designation of inactive substances would become effective 90 days thereafter.
While this action allows companies to continue manufacturing, importing or processing inactive substances for a few more months, any company doing so must submit the NOA Form B to the EPA no later than August 4th. If a company fails to meet this deadline, all activity will need to be ceased until the NOA Form B has been submitted.
For help determining if you need to fill out an NOA Form B or need help analyzing your inventory, the Environmental Scientists at CMI are ready to help.
