TSCA Services

3E Company provides support for the complex and time consuming tasks associated with regulatory compliance for the Toxic Substances Control Act (TSCA). Outsourcing this process to a team of actively involved, engaged and experienced regulatory professionals on a daily basis can be a highly efficient and effective way to address the challenges associated with ensuring compliance with chemical control laws.

TSCA services can be performed as either a defined project or on a scheduled, ongoing basis and range from fully outsourcing TSCA compliance to project-based, function-specific areas.

Support You Need, When You Need It

3E's team of TSCA Compliance professionals can perform the following:

  • Regulatory Tracking - Monitor EPA activity, federal register notices, final rules, enforcement activities, direct compliance measures and TSCA reform
  • Spearhead TSCA Compliance - Interface with your management team, regulatory personnel and others to direct and/or develop your TSCA compliance program
  • TSCA Section 5 - New Chemical Substance Compliance Support, Premanufacture Notice (PMN) requirements, Low Volume Exemption (LVE), Notice of Commencement (NOC), Bona Fide Intent to Manufacture (BFIM) requests, Polymer Exemptions, etc.
    • Consulting with client
    • Consulting with EPA – Pre-Notice Communications (PNC) 
    • Review of test data and other supporting documentation
    • Prepare toxicological evaluations and testing recommendations in support of EPA Notifications
    • Provide QSAR evaluations in the absence of test data
    • Prepare Sustainable Futures Report using EPA tools and guidance
    • Collaboration with customer chemists and regulatory personnel, industrial hygienists and other professionals
    • Preparation of notifications through ePMN/CDX PMN, LVE, BFIM, SNUN, NOC
    • Completion of electronic Form 7710-25
    • Act as Technical Contact during review 
    • Guidance on Fee Filing (3E will advise on process)
    • Serve as Technical Contact on submissions to EPA
    • Provide EPA P2 modeling assessments
  • Significant New Use Rules (SNUR)
    • Interpret and develop a compliance program
  • Chemical Data Reporting (CDR)
    • Review inventory update report requirements for current reporting period
    • Prepare Form U for submission using eCDR
    • Review current mechanisms for tracking volumes and other required information of imported and manufactured products and materials at substance level
    • If required information is not currently tracked, recommendations will be made on the best way to do so
    • Collate, categorize and compile data and information 
    • Complete report on electronic Form U for signature and submission
  • TSCA 8b Inventory Status Reviews and Certifications
  • TSCA 8c and 8e Review and Submission
  • Import Certifications - TSCA Stamp and FIFRA Notice of Arrival of Pesticides
    • Review incoming shipments for TSCA Import Status
    • Provide proper TSCA Import Certification paperwork for all shipments coming into US from overseas
    • If necessary, file FIFRA Notice of Arrival of Pesticides forms with EPA
  • TSCA 12(b) Export Notification Support
    • Review raw materials and mixtures for presence of substances subject to TSCA 12(b)
    • File any necessary Export Notifications with EPA
  • CAS RN Number and Name Application
    • CAS Inventory Expert Services request
    • Complete required documentation
  • Global Inventory Status of New Ingredients and Finished Goods
  • Training at all levels
  • On–site self assessments and audit preparedness