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EPA Issues Final Rule Requiring Submission of PMNs Using EPA’s Central Data Exchange Under TSCA Section 5 (February 2012)

In April 2010 it became required by EPA to use electronic Premanufacture Notice software when filling out TSCA section 5 Premanufacture Notice (PMN) forms. Subsequently, the objective was to phase in the use of electronic submissions via Central Data Exchange (CDX) over a two-year period. With the two-year deadline approaching, EPA has announced that submissions via CDX will become mandatory after April 6, 2012.

In order to submit documents electronically to EPA, one must register with CDX and be approved by EPA. Only Authorized Officials and Support Registrants may register with CDX. This registration process will establish the identity of the Authorized Official, which is a person in the company legally responsible for the data in the notice submission. The process also establishes the Support Registrant, which is a person designated by the Authorized Official to submit supporting documents on behalf of the Authorized Official. Note: Only the Authorized Official may submit section 5 notices.

Additionally, the registration process will:

▲ Establish the registrant’s identity, and the relation to the entity for which the registrant will submit electronic documents, with evidence that can be verified
by information sources that are independent of the registrant and the entity and that would be sufficient in identifying the registrant as the signature holder.
▲ Establish and document the correlation between the registrant and the device that will create the electronic signature of the registrant as the submitter.
▲ Require that the registrant sign on paper agreeing to protect the electronic signature from unauthorized use, be held legally responsible for the
use of the electronic signature, never delegate another to use the electronic signature or provide access to its use, maintain confidentiality of the component
in which the signature is based, and report to the entity within 24 hours if the electronic signature is compromised in any way.
▲ Provide for the immediate cancellation of the electronic signature in the event of any violation of the electronic agreement, any evidence that the signature has
been compromised, and notification from the entity that the registrant is no longer authorized to use the electronic signature to submit electronic documents
on the entity’s behalf.
▲ Require that the registrant renew his or her electronic signature once every two years or upon request by EPA.

For more information, please
Contact TSG.
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