x>EPA
United States
Environmental Protection
Agency
Office of
Toxic Substances
Washington DC 20460
April 1985
EPA 560/1-85-001
The Layman's Guide
to the
Toxic Substances
Control Act
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United States
Environmental Protection
Agency
The Layman's Guide
to the
Toxic Substances
Control Act
Office of
Toxic Substances
Washington DC 20460
April 1985
-------
Contents
Introduction 1
Scope of the Law 2
Testing of Chemicals 2
Premanufacture and Significant New Use Notifications 3
Control of Hazardous Chemicals 4
Recordkeeping and Reporting 6
Relationship to Other Federal Laws 7
Research, Monitoring, and Data Systems 9
Exports and Imports 9
Disclosure of Data 10
Effect on State Laws 10
State Programs 10
Judicial Review 11
Actions by Citizens 11
Employee Protection 11
Civil and Criminal Penalties 12
Enforcement 12
TSCA Assistance Office 12
Further Information 13
EPA Regional Offices 13
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Introduction
Chemicals—those
found in nature and
those created in labora-
tories — are at the heart
of our highly indus-
trialized, technology-
based society. They help
to protect our health and
to control pests. Chemi-
cals help clothe, shelter,
and feed us. They are
found in innumerable
products for our homes, businesses, and
industry.
The chemical industry plays a vital role in
the economy of the United States. The
production of chemicals and allied pro-
ducts accounted for roughly 5 percent of
the Gross National Product, and the in-
dustry employs about 1.1 million people.
More than 60,000 chemical substances are
presently manufactured or processed for
commercial use in the United States, and
almost one thousand more are introduced
each year.
Although most chemicals present little or
no danger to the environment or human
health when used properly, in the past few
decades some chemicals commonly used
and widely dispersed have been found to
be significantly harmful. An example is the
family of chemicals called polychlorinated
biphenyls, or PCBs. It was not until after
tens of millions of pounds of PCBs were
produced and released into the environ-
ment, however, that scientists realized how
persistent and potentially toxic they were.
Over the past few years, we have found
PCBs in our bodies and even in the milk of
nursing mothers.
In 1971, the President's Council on En-
vironmental Quality developed a legisla-
tive proposal for coping with the increas-
ing problems of toxic substances. After
five years of public hearings and debate,
Congress enacted the Toxic Substances
Control Act (TSCA) in the fall of 1976.
By enacting TSCA, Congress established a
number of new requirements and au-
thorities for identifying and controlling
toxic chemical hazards to human health
and the environment. Programs now exist
under TSCA to gather information about
the toxicity of particular chenfticals and the
extent to which people and tHte environ-
ment are exposed to them, to assess
whether they cause unreasonable risks to
humans and the environment, and to insti-
tute appropriate control actions after
weighing their potential risks against their
benefits to the Nation's economic and so-
cial well-being.
The following sections briefly describe the
major provisions of TSCA. The discussion
is intended to familiarize the public with
the provisions of the law, not to constitute
an authoritative legal statement of it.
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Scope of the Law
To ensure wise and informed decision-
making by the government, TSCA gives
the Environmental Protection Agency
(EPA) authority to gather certain kinds of
basic information on chemical risks from
those who manufacture and process
chemicals. The law also enables EPA to
require companies to test selected existing
chemicals for toxic effects, and requires
the Agency to review most new chemicals
before they are manufactured. To prevent
unreasonable risks, EPA may select from
a broad range of control actions under
TSCA, from requiring hazard-warning
labels to outright bans on the manufac-
ture or use of especially hazardous
chemicals. EPA may regulate a chemical's
unreasonable risks at any stage in its life-
cycle: the manufacturing, processing,
distribution in commerce, use, or
disposal.
Eight product categories are exempt from
TSCA's regulatory authorities: pesticides,
tobacco, nuclear material, firearms and
ammunition, food, food additives, drugs,
and cosmetics. Many of these product
categories are regulated under other Fed-
eral laws.
Testing of Chemicals
TSCA gives EPA authority to require
manufacturers or processors of certain ex-
isting chemicals (i.e., those already being
distributed in commerce) to test their
health and environmental effects. EPA ex-
ercises this authority only when it can
make certain statutory findings about the
substance involved and when industry
fails to develop the needed data on its
own. These required findings are: (1) that
there are insufficient data already available
with which to perform a reasonable risk
assessment; (2) that testing is necessary
to provide such data; (3) that a chemical
may present an unreasonable risk of injury
to human health or the environment; or
(4) that the chemical is produced in sub-
stantial quantities resulting in significant
human exposure or environmental release.
Testing requirements are imposed only
after a rulemaking proceeding which in-
cludes opportunities for both public com-
ments and an oral presentation at a
hearing.
An Interagency Testing Committee of gov-
ernment experts on chemical substances
advises EPA on those that should be
tested; however, actions are not limited to
those recommended by the Committee.
The eight Committee members represent
the Departments of Labor, Commerce,
Health and Human Services (including the
National Cancer Institute, the National In-
stitute for Occupational Safety and Health,
and the National Institute of Environmental
Health Sciences), the National Science
Foundation, the Council on Environmental
Quality, and EPA. The Committee desig-
nates priority chemicals for testing. Then,
EPA either initiates rulemaking for testing
requirements for designated chemicals or
publishes the reasons why testing is not
required.
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Premanufacture and
Significant New Use
Notifications
The authors of TSCA recognized that
health and environmental considerations
are more easily addressed before, rather
than after, a chemical is produced and in-
troduced into commerce.
Thus, manufacturers or importers of new
chemicals must give EPA a 90-day advance
notification of their intent to manufacture
or import a new chemical, except for those
chemical categories specifically excluded by
TSCA. Any chemical which is not listed
on the inventory of existing chemicals
(discussed in "Recordkeeping and Report-
ing" section), published by the Agency, is
considered "new" for purposes of this
premanufacture notice requirement.
In addition, EPA may designate a use of a
chemical as a significant new use, based
on consideration oiseveral factors, includ-
ing the anticipated extent and type of ex-
posure to human beings or the environ-
ment. Anyone who intends to manufac-
.
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ture, import or process a chemical for
such a significant new use (even rf the
chemical is on the inventory and/or went
through premanufacture notification re-
view) must notify EPA 90 days before
manufacturing, importing or processing
the chemical for that use.
The 90-day review period for new chemi-
cals and significant new uses can be ex-
tended by EPA for an additional 90 days for
a good cause. Notices submitted for new
chemicals, or significant new uses of
chemicals, are to include: the identity of
the chemical, its molecular structure, pro-
posed categories of use, an estimate of the
amount to be manufactured, imported or
processed, the byproducts resulting from
the manufacture, processing, use, and dis-
posal of the chemical, estimates of expo-
sure and any test data related to the hearth
and environmental effects of the chemical.
In addition, if a rule requiring testing of the
chemical or its chemical class has been
issued, the notice must include test data
developed from that testing along with the
other information.
Chemicals produced in small quantities
solely for experimental or research and
development purposes are automatically
exempt from the premanufacture and sig-
nificant new use notification requirements.
In addition, any person may apply for an
exemption for chemicals used solely for
test marketing purposes or those deter-
mined by EPA not to present an unreason-
able risk of injury to human heatth or the
environment
If EPA determines tfiat insufficient informa-
tion is in a notification to evaluate potential
risk, the Agency may orderthat the manu-
facture or importation of the chemical be
prohibited until adequate data are devel-
oped. The company is under no time limit
to submit the information, but until it does,
EPAs ban remains in efect After review-
ing a premanufacture notification, contain-
ing sufficient data, if EPA determines that
the new chemical presents or wiH present
an unreasonable risk of injury to health or
the environment the Agency can during
the review period prohibit the manufactur-
ing, processing, or distribution in com-
merce of that chemical,
Control of Hazardous
Chemicals
Under T8CA, EPA has the authority to
prohibit or fcmrt the manufacture, import,
processing, distribution in commerce, use,
or disposal* of a chemical when these ac-
tivities are found to pose an unreasonable
risk of injury to human health or the en-
vironment, A number of possible control
options are available, ranging from total
prohibition to bbefng.
"Distinction Between Disposal Authority of
TSCA &RCRA: TSCA hat the authority to regu-
late the dwposal stage of a ctemicars fife cycle
onachemicaMjy-chem«ca(ba««,thaci»,oncea
particular chemical is determined to be an urv
reasonable risk to human health and the envi-
ronment (04,, PC8#). The Resource Conserva-
tion and Recovery Act (RCRA) has the authority
to ertabfoh regulation* and programs to en-
surc safe waste treatment and olsposal of any
*- - -* «• * * 0*^4 I II I «
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A manufacturer or processor may be re-
quired to make and keep records of the
processes used in manufacturing a chemi-
cal and to conduct tests to assure com-
pliance with any regulatory requirements.
Further, the Agency may require a manu-
facturer or processor to give notice of any
unreasonable risk of injury presented by
his chemical to those who purchase or
may be exposed to that substance. A
manufacturer or processor may also be
required to recall a substance which pre-
sents an unreasonable risk.
In proposing regulatory actions, EPA must
provide an opportunity for comments by
all interested parties.
A rule limiting, but not banning, a chemical
may be made immediately effective when
initially proposed in the Federal Register if
the Agency determines that the chemical
is likely to present an unreasonable risk of
serious or widespread injury to health or
the environment before normal rutemak-
ing procedures could be completed. In the
case of a rule prohibiting the manufacture
of the chemical, EPA must first obtain a
court injunction before the rule can be
made immediately effective.
For those chemicals that present an immi-
nent and unreasonable risk of serious or
widespread injury to health or the envi-
ronment EPA may ask a court to require
whatever action may be necessary to pro-
tsct against such risk, (EPA also
cooperates wWi other agencies In toxic
chemical control. See Relationship to
Other Law*, page 1,\
In addition to using various control op-
tions, EPA warns the pubic about chem-
ical hazards through its chemical advisory
program. Chemical advisories encourage
individuals or organizations to voluntarily
reduce the risks associated with a chem-
ical, such as the risk of continual contact
with used motor oil. Chemical advisories
dscuss toxic effects of chemicals of con-
cern, routes of exposure, and alternative
methods of reducing risks.
PofycMorinated Biphenytt (PCBs). In
TSCA, Congress singled out PCBs for both
immediate regulation and phased with-
drawal from the market EPA may au-
thorize certain uses of PCBs and may
exempt, pursuant to certain TSCA criteria,
specific activities involving the manufactur-
THIS
EQUIPMEN
CONTAINS
APACITORC
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ing, processing, or distribution in com-
merce of PCBs. PCBs are of concern be-
cause tests on laboratory animals show
that chronic exposure to PCBs may cause
reproductive failures, gastric disorders,
skin lesions, and tumors. Moreover, PCBs
persist and when released into the envi-
ronment tend to accumulate in tissues of
living organisms. This means that, as PCBs
move up in the food chain toward hu-
mans, their concentration, and thus their
potential for harm, increases.
Recordkeeping and
Reporting
A major challenge for the TSCA program
was to develop a mechanism for identi-
fying those chemicals likely to damage
human health or the environment so that
appropriate action could be taken by in-
dustry or EPA.
In fact, Congress recognized during its
discussion on TSCA that very little was
known about chemicals in the environment.
When the law was passed, it was not even
known how many chemicals there were, in
what quantities they were produced and
where, what their byproducts were, who
was exposed to them and under what
conditions. This information was available
only for a handful of existing chemicals.
Therefore, Congress gave EPA the author-
ity to compile an inventory of existing
chemical substances, and to develop
additional information on these basic
questions.
The first inventory was published in 1979,
based on information reported to EPA by
chemical manufacturers, importers, and
processors. The inventory— to which new
chemicals are added when they go into
production — shows now that nearly
58,000 commercial chemical substances
are, or have been, manufactured or im-
ported into the United States since Janu-
ary 1,1975. (There are well over 5 million
known chemical compounds, but most are
research and development chemicals that
are not used commercially.)
It is important to note that the chemical
inventory is not a list of toxic or hazardous
chemicals. Rather, it lists existing chemi-
cals by their specific chemical name (e.g.,
acetonitrile, bromobenzene, chlor-
methane, etc.), giving for the first time an
overall picture of the chemicals used for
commercial purposes in the United States.
In addition to being unprecedented, this
list is of major importance because chemi-
cals not on the inventory must be re-
viewed by EPA under the premanufacture
notification program before they are al-
lowed into U.S. commerce. In addition to
compiling the inventory, EPA has used its
TSCA reporting authority to obtain produc-
tion, use, release, and exposure data on a
number of chemicals — including asbestos
and chemicals recommended by the In-
teragency Testing Committee for test rule
consideration.
TSCA also requires any person who manu-
factures, processes, or distributes in com-
merce any chemical substance or mixture
to keep records of significant adverse reac-
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tions to health or the environment that al-
legedly were caused by the chemical. Rec-
ords concerning health effects on em-
ployees must be kept for 30 years; other
records must be retained for 5 years.
The Agency may require the submission
of health and safety studies which are
known or available to those who manufac-
ture, process, or distribute in commerce
specified chemicals.
In addition, if the chemical industry has
information which indicates that a chemi-
cal presents a substantial risk of injury to
health or the environment, EPA must be
notified. Substantial-risk reporting has
heightened industry's awareness of poten-
tial chemical risks, often resulting in manu-
facturers, processors, and distributors tak-
ing action on their own to minimize expo-
sure to hazardous substances.
Relationship to Other
Federal Laws
TSCA explicitly requires EPA to coor-
dinate its activities with those of other
Federal programs involved in toxic
chemical control administered by
organizations such as: The Consumer Pro-
duct Safety Commission, The Food and
Drug Administration, The Department of
Agriculture, The Occupational Safety and
Health Administration, The Department of
Transportation, The Department of
Health and Human Services, and others.
EPA may determine that an unreasonable
risk presented by a chemical may be pre-
vented or sufficiently reduced by action
under a Federal law it does not administer.
If so, a request to the agency administering
the other law is made to determine
whether the risk exists and if the other
agency's action would sufficiently reduce
the risk. If the agency finds no risk or takes
action directed to the risk, EPA may then
not take any regulatory action directed to
that same risk.
TSCA also directs EPA to use other laws it
administers — such as the Resource Con-
servation and Recovery Act or the Clean
Water Act — to protect against unreason-
able risks unless a determination is made
that it is in the public interest to protect
against such risks under TSCA.
The following major laws are
administered by EPA.
• Clean Water Act, as amended, is the
basic authority for water pollution control
programs. The goal of the act is to make
national waters fishable and swimmable.
• Safe Drinking Water Act, as amended
in 1977, permits EPA to regulate the quality
of water in public drinking water systems
and the disposal of wastes into injection
wells.
• Resource Conservation and
Recovery Act of 1976 ("RCRA") authorizes
EPA to establish regulations and programs
to ensure safe waste treatment and
disposal.
• Federal Insecticide, Fungicide, and
Rodenticide Act ("FIFRA"), as amended,
directs EPA to regulate the manufacture,
distribution and use of pesticides and con-
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duct research into their health and en-
vironmental effects.
• Toxic Substances Control Act of 1976
("TSCA"), provides authority to regulate
the manufacture, distribution and use of
chemical substances.
• Clean Air Act, as amended in 1977, pro-
vides the basic legal authority for the na-
tion's air pollution control programs, and is
designed to enhance the quality of air
resources.
• Comprehensive Environmental Re-
sponse Compensation and Liability Act
of 1980 ("Superfund") establishes a pro-
gram to deal wrth release of hazardous
substances in spills and from inactive and
abandoned disposal sites.
• Marine Protection, Research, and
Sanctuaries Act of 1972 permits EPA to
protect the oceans from the indiscriminate
dumping of waste.
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Research, Monitoring, and
Data Systems
In order to fully meet statutory re-
quirements, EPA and other Federal agen-
cies have expanded research and related
activities.
The EPA Research Committee system has
been established to serve as a cornerstone
for program planning in the Office of
Research and Development (ORD) and to
effect a formal liaison between ORD and
the other program offices within EPA.
The Chemical Testing and Assessment
Research Committee (CTARC) plans re-
search activities relevant to TSCA.
In addition to establishing a data system
within EPA for information submitted
under TSCA, the Agency is designing and
establishing a system for lexicological and
other scientific data accessible to all
Federal agencies.
EPA has developed the Chemicals-in-
Commerce Information System (CICIS) to
store and retrieve TSCA data. This system
contains TSCA confidential business in-
formation and state-of-the-art computer
security techniques. The computerized
TSCA Inventory became operational in late
1979, and several information services
have derived from it, including subsys-
tems for Freedom of Information Act re-
quests, inventory profiles for EPA Regional
Offices, support for the TSCA premanufac-
ture review process, and health and safety
study submissions.
The Interagency Toxic Substances Data
Committee (ITSDC), formed in February
1978 by EPA and the Council on Environ-
mental Quality, is continuing its work to
construct a comprehensive Chemical Sub-
stances Information Network (CSIN).
CSIN enables toxic substances information
users to have access to a number of inde-
pendent and autonomous data banks in
the public and private sectors. Users can
make use of one computer to manage the
logging-in, accessing, and processing of
their queries for relevant records in and
among many data and information sys-
tems — one simple access point to a
"library of systems."
Through the ITSDC, EPA is responsible for
the day-to-day administration of CSIN,
which became operational in November of
1981. CSIN significantly advances the
availability of chemical data to both gov-
ernmental and private sector organizations
to efficiently resolve and manage issues
concerning chemical substances.
Exports and Imports
If a person intends to export a chemical
which is subject to certain requirements
under TSCA, he must notify EPA. The
Agency is responsible for notifying the im-
porting country's government of the ex-
port and of EPA's regulatory action or the
availability of information.
With respect to imports, no chemical sub-
stance, mixture, or article containing a
chemical substance or mixture will be al-
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lowed into the customs territory of the
United States if it fails to comply with any
TSCA rule or otherwise violates TSCA.
TSCA requirements generally relate to
substances that are produced and
distributed in U.S. commerce. However,
chemical substances produced in the
United States but for export only, can be
covered by TSCA if EPA finds that the
chemical substance will present an
unreasonable risk within the U.S. EPA
may require that the chemical substance
be tested, and may further regulate it.
Disclosure of Data
Confidential data, such as trade secrets
and privileged financial data, will be pro-
tected from disclosure by EPA. All health
and safety information, submitted under
TSCA, on chemicals in commerce is sub-
ject to disclosure. A person submitting
other types of data to EPA may designate
any part of them as confidential. EPA will
treat such information as confidential unti!
the Agency determines that the informa-
tion is not entitled to such protection. If
the release of confidential business infor-
mation is essential for the protection of
health or the environment, EPA may dis-
close it after notifying the person who
submitted the data in advance of any con-
templated release.
Effect on State Laws
With certain exceptions, TSCA will not
affect the authority of any State or political
subdivision to establish regulations con-
cerning chemicals. If EPA issues a testing
requirement for a chemical, a State may
not establish a similar one for the same
purposes. If EPA restricts the manu-
facture or otherwise regulates a chemical
under TSCA, a State may only issue re-
quirements which are identical, are man-
dated by other Federal laws, or prohibit the
use of the chemical. In response to a re-
quest by a State, ERA may grant an
exemption to allow the State to regulate
differently from TSCA regulatory actions
under certain conditions. Specifically, ERA
can grant exemptions if the State require-
ment (1) would not cause a person or activ-
ity to be in violation of a requirement
under TSCA and (2) would provide a
greater degree of protection and not un-
duly burden interstate commerce.
EPA is actively committed to a policy of
delegating more authority and decision-
making power to the States to implement
TSCA.
State Programs
TSCA authorizes grants to be awarded to
States to help establish programs to pre-
vent or eliminate unreasonable risks as-
sociated with toxic substances. Seven
States and Puerto Rico were recipients of
such grants in 1979, 1980, and 1981. The
projects funded, which will be completed
and evaluated in 1983 and 1984, ranged in
scope from developing toxic substances
data bases to establishing State strategies
to investigate and, if necessary, control
unreasonable risks.
In addition, a Regional and State Relations
Program to promote cooperative ap-
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preaches to dealing with toxic substances
problems was begun. The program's de-
sign and initial efforts came from recom-
mendations made in a 1961 report submit-
ted by the National Governors' Association
(NGA), which studied, with the help of an
EPA grant, how States manage toxics
problems. Subsequently, grants to NGA
were awarded to coordinate the States' ac-
cess to EPA's Chemical Substances Infor-
mation Network (CSIN), to act as a clear-
inghouse to publicize State toxic sub-
stances management practices and to
allow experts from one State to advise
their counterparts in another. In addition, a
conference attended by twenty-six State
representatives was held.
During the 1982 State legislative sessions,
issues concerning integrated toxics man-
agement were monitored and a report on
trends was issued. The toxics manage-
ment activities were reviewed and as-
sessed yielding profiles of eighteen States'
programs from which needs analyses are
being drawn.
These activities and others will further de-
velop EPA's cooperative relationship with
States and an integrated approach to deal-
ing with toxic substances.
Judicial Review
Not later than sixty-days after a rule is
promulgated under certain TSCA pro-
visions, a person may file a petition for
judicial review of such rub with the U.S.
Court of Appeals for the District of Col-
umbia Circuit or with the U.S. Court of
Appeals for the circuit of his residence or
business.
Actions by Citizens
Any person may bring a civil suit to
restrain a violation of TSCA by any party
or to compel the Agency to perform any
nondiscretionary duty required by this law.
In addition, any person may petition EPA
to issue, amend, or repeal a rule under the
testing, reporting, or restriction sections of
TSCA. The Agency has 90 days to respond
to a petition. If no action is taken or a
petition is denied, the party has the op-
portunity for judicial review in a U.S.
District Court. In both civil suits and
citizens' petitions, the court may award
reasonable legal costs and attorneys' fees,
if appropriate.
Employee Protection
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If an employee believes that his employer
has discriminated against him because of
the employee's participation in carrying
out TSCA, he may file a complaint with
the Secretary of Labor. The Secretary
shall investigate the alleged discrimination
and, if warranted, may order the employer
to remedy the effects of any such discrim-
inatory action. Employees and employers
may obtain judicial review in the U.S.
Courts of Appeals.
EPA will evaluate the potential effects on
employment of regulatory actions under
TSCA. In response to a petition by an
employee, EPA may investigate and hold
public hearings concerning job losses or
other adverse effects allegedly resulting
from a requirement under TSCA. The
Agency will make public these findings
and recommendations.
Civil and Criminal
Penalties
Any person who fails or refuses to comply
with any requirement made under TSCA
may be subject to a civil penalty of up to
$25,000 for each day of violation. Persons
who knowingly or willfully violate the law,
in addition to any civil penalties, may be
fined up to $25,000 for each day of viola-
tion, imprisoned up to a year, or both.
Enforcement
EPA can inspect any establishment in
which chemicals are manufactured, pro-
cessed, imported to, stored, or held
before or after their distribution in com-
merce. No inspection shall include finan-
cial, sales, pricing, personnel, or research
data, unless specified in an inspection
notice.
The Agency can subpoena witnesses,
documents, and other information as nec-
essary to carry out TSCA.
Civil actions concerning violations of or
lack of compliance with TSCA may be
brought to a U.S. district court to restrain
or compel the taking of an action. Any
chemical substance or mixture that was
manufactured, processed, or distributed in
commerce in violation of TSCA may be
subject to seizure.
Specific enforcement strategies for im-
plementing TSCA regulations have been
developed by the Agency. These strategies
identify and rank possible violations of a
particular regulation, identify the tools
available for compliance monitoring and
how they will be used, provide a formula
for determining application of inspection
resources, and establish policy for deter-
mining civil penalties under the regulation.
TSCA Assistance Office
As required by TSCA, EPA has estab-
lished an office to provide technical and
other nonfinancial assistance to chemical
manufacturers, processors and others
who are interested in requirements and
activities under this law. To help people
understand TSCA's requirements, the
TSCA Assistance Office (TAO) provides a
toll-free telephone information service, a
bi-monthly bulletin, and other technical
assistance upon request.
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Further Information
To obtain up-to-date information on TSCA
requirements, call the TSCA Assistance
Office's toll-free line: 800-424-9065
(554-1404 in Washington, D.C.). Outside
of the United States call 202-554-1404.
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EPA REGIONAL OFFICES
Regional Offices
EPA Region 1
JFK Federal Building
Boston, MA 02203
EPA Region 2
26 Federal Plaza
New York, NY 10278
EPA Region 3
841 Chestnut Street
Philadelphia, PA 19107
EPA Region 4
345 Courtland St., NE
Atlanta, GA 30365
EPA Region 5
230 South Dearborn Street
Chicago, IL 60604
G>
EPA Region 6
1201 Elm St.
Dallas TX 75270
EPA Region 7
726 Minnesota Avenue
Kansas City, KS 66101
EPA Region 8
1860 Lincoln Street
Denver, CO 80295
EPA Region 9
215 Fremont St.
San Francisco, CA 94105
EPA Region 10
1200 Sixth Avenue
Seattle, WA 98101
States Covered
Connecticut, Maine,
Massachusetts, New Hampshire,
Rhode Island, Vermont
New Jersey, New York,
Virgin Islands, Puerto Rico
Delaware, Maryland,
Pennsylvania, Virginia,
West Virginia,
District of Columbia
Alabama, Florida, Georgia,
Kentucky, Mississippi,
North Carolina, South
Carolina, Tennessee
Indiana, Illinois,
Michigan, Minnesota,
Ohio, Wisconsin
Arkansas, Louisiana,
New Mexico, Oklahoma,
Texas
Iowa, Kansas, Missouri,
Nebraska
Colorado, Montana, North
Dakota, South Dakota,
Utah, Wyoming
Arizona, California,
Hawaii, Nevada,
American Samoa, Guam,
Trust Territories of
the Pacific, Wake Island
Alaska, Idaho, Oregon,
Washington
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