TSG Advisory: Events

TSG & MLA TSCA Course (April 29-30, 2013)

This course begins with an overview of the Toxic Substances Control Act (TSCA) for those who are new to this law or who need to refresh their understanding.  The course continues with detailed presentations concerning the many TSCA requirements that regulate the manufacture, import, processing, distribution, use, and export of chemical substances and products that contain them.  

Presented continuously since 1988, this course remains the best of its kind for attorneys and for regulatory, customs, purchasing, product safety, research, and technical professionals. This intensive day-and-a-half course includes the following:

▲ The purpose and scope of TSCA, including the chemical products and commercial activities that fall under the
jurisdiction of this law
▲ How the U.S. Environmental Protection Agency (EPA) administers and enforces TSCA requirements for manufacturing,
importing, processing, distributing, using, and exporting chemical substances and mixtures
▲ How to use the TSCA Chemical Substances Inventory to determine what chemicals may be manufactured in or imported into
the United States, how to prepare premanufacture notices (PMNs) for new chemical substances, and how to apply the many
exemptions from the PMN requirement
▲ How to comply with TSCA requirements for importing and exporting chemical substances and mixtures
▲ How to comply with the many reporting and recordkeeping requirements under TSCA, and how to collect, screen, and report
"substantial risk" information to EPA under section 8(e) of TSCA
▲ How to comply with EPA's TSCA Chemical Data Reporting Rule (formerly the Inventory Update Rule) and
Canada's Domestic Substances List Inventory Update Phase 2 Mandatory Survey (due this year) What EPA is doing to
manage existing chemicals under TSCA
▲ The status of Congressional efforts to amend TSCA
▲ How to protect confidential business information when making submissions to EPA
▲ EPA's enforcement priorities under TSCA
▲ How to manage for TSCA compliance within your company
▲ How to use EPA's Audit Policy as a management tool to identify and correct TSCA violations and to secure a waiver of civil
penalties by voluntarily disclosing them to EPA
▲ We are pleased to announce that the Spring 2013 TSCA Seminar has been approved for CLE credit by The Virginia State Bar.
A Uniform Certificate of Attendance will be provided for use when applying for credit in other jurisdictions.

For more information, please contact lmoreno@mckennalong.com.

Register Now!

Law Offices of McKenna Long & Aldridge LLP 
1900 K Street,
NW  Washington, DC 20001    

Day 1  
Registration / Breakfast: 8:00 am 
Program: 8:30 am - 5:00 pm
Cocktail Reception: 5:00 pm - 6:00 pm  

Day 2 
Breakfast: 8:00 am  
Program: 8:30 am - 3:00 pm   

Registration Fee:
Early Registration: $550  
After March 25: $650   

Registration fee includes program materials, breakfast, lunch, a cocktail reception on site, and a complimentary copy of the TSCA Handbook.

Day One Agenda and Course Outline
8:00 am Registration; Coffee and Pastries
8:30 am Introduction to TSCA
Thomas B. Johnston, McKenna Long & Aldridge LLP
▲ Goals of TSCA
▲ Scope of TSCA (chemical substances, mixtures, articles)
▲ Key TSCA terms
▲ Activities subject to TSCA (manufacturing, processing, use, distribution, disposal)
9:00 am Introduction to TSCA
Saadia Eltayeb, Ph.D., Technology Sciences Group, Inc.
▲ Development of the TSCA Initial Inventory
▲ Inventory nomenclature
▲ Inventory corrections
▲ Structure of the Inventory
▲ Bona Fide Intent to Manufacture Notices
10:00 am Break
10:15 am Premanufacture Notices: The Critical Requirement for Importers and Manufacturers
Stanley W. Landfair, McKenna Long & Aldridge LLP 
▲ Exclusions and exemptions
11:30 am Preparing a PMN and Seeing It Through EPA's Review 
Will Pettit, Technology Sciences Group, Inc.
12:30 pm Luncheon Presentation: EPA's TSCA Enforcement Entities
Rosemarie A. Kelley, Director, Waste and Chemical Enforcement Division, Office of Enforcement and
Compliance Assurance, EPA
1:30 pm EPA's Regulation of New Chemicals and New Uses
Michael Boucher,  McKenna Long & Aldridge LLP 
▲ Section 5(e) consent orders
▲ Significant New Use Rules
▲ Regulation of nanoscale materials under TSCA
2:30 pm Import and Export Requirements 
Thomas B. Johnston, McKenna Long & Aldridge LLP 
3:00 pm Break
3:15 pm EPA's Preliminary Assessment Information Rules and Section 8(d) Reporting Requirements for Health and Safety Studies
Michael Boucher,  McKenna Long & Aldridge LLP 
▲ Basic requirements
3:45 pm Test Rules
Thomas B. Johnston, McKenna Long & Aldridge LLP
▲ Selection of chemicals for consideration
▲ Section 4's test rule authority
▲ High Production Volume Challenge
4:15 pm Managing for TSCA Compliance
Andrea V. Malinowski,  Corporate Counsel, E.I. du Pont de Nemours and Co.
5:00 pm Cocktail Reception
Day Two Agenda & Course Outline
8:00 am Coffee & Pastries
8:30 am EPA's Chemical Data Reporting Rule and Canada's Domestic Substances List Inventory Phase 2
Will Pettit, Technology Sciences Group, Inc.
▲ Lessons learned from 2012 CDR Rule and preparing for 2016
▲ Canada's Domestic Substances List Inventory Update Phase 2 (2013)
9:45 am Break
10:00 am Section 8(c)  Recordkeeping for Reports of "Significant Adverse Reactions" and Section 8(e) Reporting of "Substantial Risk" Information
Thomas B. Johnston, McKenna Long & Aldridge LLP 
11:00 am EPA's Existing Chemicals Management Program under TSCA
Michael Boucher,  McKenna Long & Aldridge LLP 
▲ Status of and prospects for modernizing TSCA
▲ EPA's authority under and use of section 6
▲ TSCA Work Plan Chemicals
11:45 am Protecting Confidentiality of Information Submitted to EPA
Thomas B. Johnston, McKenna Long & Aldridge LLP
▲ EPA's Confidential Business Information Challenge 
12:15 pm Lunch
1:00 pm Preparing for TSCA Inspections and Limiting Liability for Violations
Stanley W. Landfair, McKenna Long & Aldridge LLP 
▲ What to expect when you are inspected by EPA
▲ Effective use of EPA's Self-Policing Policy ("Audit Policy")
2:15 pm Summary & Wrap-Up
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