SBA Advocacy Environmental Roundtable, May 30, 2019

The next U.S. Small Business Administration, Office of Advocacy Environmental Roundtable will meet to discuss the following topics, beginning at 10 a.m. on Thursday, May 30, 2019.  The meeting will be held in Washington, D.C., at the Small Business Administration Headquarters, 409 Third Street SW, Eisenhower B Conference Room.  Send your RSVP to  Please indicate whether you are attending in person, or by teleconference.  Information will be sent out to you when you RSVP.  We have adopted a casual attire option for all Roundtable meetings.


10:00 – 11:00 AM                     Chemical Data Reporting Revisions and Small Manufacturer Definition Update Under TSCA Section 8(a)

Susan Sharkey, Existing Chemicals Branch, Office of Pollution Prevention and Toxics, EPA

Roundtable meetings are open to all interested persons, with the exception of the press, in order to facilitate open and frank discussion about the impacts of Federal regulatory activities on small entities.  Agendas and presentations are available to all, including the press. Anyone who wants to receive roundtable agendas or presentations, or to be included in the distribution list, should forward such requests to  The purpose of these Roundtable meetings is to exchange opinions, facts and information and to obtain the attendees’ individual views and opinions regarding small business concerns.  The meetings are not intended to achieve or communicate any consensus positions of the attendees.

Small Business Environmental Roundtable

Issue for Discussion

May 30, 2019

EPA’s Proposed Rule for Chemical Data Reporting Revisions and Small Manufacturer Definition Update Under TSCA Section 8(a)

On April 25, 2019, EPA published proposed revisions to its Chemical Data Reporting (CDR) requirements under section 8(a) of the Toxic Substance Control Act (TSCA).  The CDR rule requires chemical manufacturers (including importers) to report data on chemical manufacturing, processing and use every four years.  Among the changes proposed, EPA is modifying its requirements for confidentiality claims, replacing certain processing and use codes, and revising the definition of “parent company.”  EPA is also proposing to add a few new elements, including a requirement to report the NAICs code for the site of manufacture and a requirement to identify volume production of a byproduct.  In addition, EPA is also proposing to exempt specific byproducts that are recycled on-site and to allow category reporting for inorganic byproducts.

EPA also chose to include an update of its small manufacturer definition under TSCA section 8(a) in this proposed rule.  EPA is proposing to adjust the existing small manufacturer definition for inflation.  For the first standard, EPA is adjusting the revenue threshold from $40 million to $100 million (retaining the original 100,000 pounds volume qualifier) and for the second standard, from $4 million to $11 million.  Under CDR, sites that meet the small manufacturer definition are exempt from reporting, with some exceptions.

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