Richard Denison, Ph.D., is a Senior Scientist.
I noted in an earlier post that the American Chemistry Council (ACC) is seeking major delays in the implementation of enhanced chemical information reporting requirements that EPA has proposed under its TSCA Inventory Update Rule (IUR). But ACC isn’t content with just delaying the enhanced reporting. It’s also seeking an exemption so large that it literally threatens to swallow much of the rule.
The proposed exemption is called for in a footnote on page 2 of the comments ACC filed on the proposed rule: “Exemptions should be provided for any company engaged in an acquisition or divestiture during the years since the last reporting cycle.”
Just how large an exemption would that be? Read More