by Citation News Editor
16. October 2011
How ART Notifications Work
The US EPA warned in August of upcoming changes to the way it collects information from commercial chemical manufacturers, adding the Chemical Data Reporting (CDR) rule. Published in the Federal Register on August 16 as 40 CFR 711, the new rule went into effect on September 15.
The CDR rule, which replaced the Inventory Update Reporting rule, enables the EPA to collect and publish information on the manufacturing, processing and use of commercial chemicals on the Toxic Substances Control Act's (TSCA) Chemical Substance Inventory. The main points of the CDR include more frequent reporting, reduced reporting thresholds for specific chemicals, new exemptions, and new reporting requirements.
Under TSCA, failure to maintain required records or to report the required information can result in civil penalties of up to $25,000 a day as well as criminal fines and imprisonment. Users of Citation's CyberRegs could have found the new CFR material the day it was released, and might have even received email notification that 40 CFR 711 had changed. But unless they were following closely, they might have missed the specific changes pertaining to their practices and procedures.
ART users not only received an automatic email notification that relevant changes were made in the company's ART Review, but they were given specific changes in eight Detailed Requirements. They would have not only known that previously written compliance tasks for the replaced Inventory Update Reporting rule were outdated, but they would have realized immediately how they needed to alter their reporting thresholds or frequency, or if they received a new exemption.
Citation's regulatory analysts would have done the leg work for them, providing them specific citations to the material that contained the necessary compliance actions. For example, the Detailed Requirement for 40 CFR 711.20 tells users they must "File reports during applicable submission periods" and 40 CFR 711.35 tells users to "Submit reports electronically pursuant to requirements."
The ART notifications contain the citation and full text of the rule that was changed. Users simply have to look up the citations and make the necessary changes within their compliance matrix. In this manner, the company will always be in compliance with the standards of the federal government.
