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NPRA on EPA chemical reporting rule

Hydrocarbon Engineering,

NPRA Vice President of Petrochemicals James Cooper issued the following statement statement regarding the EPA Chemical Data Reporting (CDR) rule announced on 2nd August, previously known as the Toxic Substances Control Act Inventory Update Reporting (IUR) modifications:

‘EPA showed sound judgment when it decided to retain a threshold of reporting on chemicals produced to 25 000 lbs/y, and not lower it. Additionally, by moving the reporting period to early 2012, producers are better able to gather, consolidate and provide more accurate information.’

‘EPA’s decision to increase the type and amount of information it collects from commercial chemical manufacturers is imprudent and imposes unrealistic requirements on petrochemical manufacturers and others that sell commodity chemicals. Requiring them to report us and exposure information of the chemicals when many of their customers are traders and distributors is analogous to requiring the manufactures of Girl Scout cookies to track who eats every box.’

‘This rule will dramatically increase the reporting burden on manufacturers and requires more information than the EPA can feasibly use. We recommend that EPA use Section 8(a) of TSCA in a more targeted manner, such as the PAIR rule, which collects exposure information as it is needed, and is what Congress intended when it crafted the statute.’

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