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Dealing with chemicals or toxic substances is a sensitive business. A lot of harm can be caused if guidelines to govern the same are not set in place. This is why a federal regulation known as the Toxic Substances Control Act (TSCA) has been set in place so as to effectively manage chemical commerce in the country. Companies that fall under their jurisdiction must ensure that they adhere to the set regulations. These regulations can sometimes prove to be complex, making it difficult for laboratories to be able to comply with them. As such, the following guide has been compiled to help you with TSCA compliance.
What is TSCA Applicability to Your Laboratory?
In order to ensure that your business is in compliance to the TSCA guidelines, you should start by first checking how applicable they are to your laboratory. For this, you may require some guidance. You can therefore choose to seek the help of TSCA compliance services. If you are going about it on your own, you can use certain guides that have been set in place. One of them is the TSCA Applicability Determination Decision Tree. Once you have completed this, you can then go ahead and take the Targeted Chemical Reporting Survey.
There are usually five questions that are presented when the survey is completed which will help to determine what you require for TSCA compliance. This applies if your answer ticks yes to one or more of the questions asked. If this is the case, there will be an email that will be forwarded to you which will contain information regarding that actions that you need to take in order to comply with TSCA regulations. You should also note that this is not a one off process. This is especially if your business is growing and is likely to experience some changes in terms of day to day laboratory operations. This may affect your TSCA applicability requiring you to retake the survey.
Appoint a TSCA Coordinator for Your Laboratory
Now that you are aware of the TSCA regulations that you need to agree to, it is necessary that you maintain compliance by managing the operations of the laboratory. However, this can be difficult to do if you are running the company and you are not hands on. This is why it would help if you hired a TSCA coordinator. This is a person who will play the role of managing the lab and ensure that the TSCA are being complied to. There are certain qualifications that you should look for in a TSCA coordinator. They should be technically qualified to understand chemicals in general and the specific operations of the lab.
Start Compiling Your TSCA Compliance File
TSCA compliance is an ongoing process. The program is especially record intensive. This means that your records will be the main focus during TSCA compliance inspections. It is therefore crucial that you come up with a TSCA compliance file and always ensure that it is up to date. It should also contain all the necessary documentation. This includes documents such as the TSCA Applicability Determination form, import certifications, exports notifications and so on.
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