On January 19, 2017, the Environmental Protection Agency (EPA) announced an interpretation of Section 14 of TSCA relating to non-exempt CBI claims. This interpretation requires manufactures who make or process chemicals covered under TSCA to claim confidential business information (CBI) at the time of submittal. Starting August 15, 2019, the EPA will no longer issue notice of deficiencies (NOD) to companies that submit defective non-exempt CBI claims. After August 15, 2019 businesses that submit a deficient CBI claim will receive a written notification that the claim is invalid and the information will not be treated as confidential. Due to this, please ensure that the proper procedure is followed for TSCA CBI submittals because the EPA will not provide you with a chance to correct a deficient submittal.

If you need assistance with this process please contact  Sarah Carty at  sarahc@smithmanage.com for assistance.