July 27, 2018
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• U.S. Environmental Protection Agency	18 P-0226
	 \ Office of Inspector General
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At a Glance
Why We Did This Project
The U.S. Environmental
Protection Agency (EPA),
Office of Inspector General
(OIG), conducted this audit to
determine (1) how the EPA is
ensuring that companies are
compliant with Chemical Data
Reporting (CDR) Rule
requirements under the Toxic
Substances Control Act (TSCA)
and (2) whether the EPA is
using CDR data to prioritize
chemicals for the purpose of
identifying their potential risks
to human health and the
environment.
Under the CDR Rule, the EPA
collects information about the
types, quantities and uses of
chemical substances produced
domestically and imported into
the United States. The EPA
uses this information, which
manufacturers and importers
are required to submit every
4 years, to screen and prioritize
chemicals for the purpose of
identifying potential human
health risks and environmental
effects, per the methodology
outlined in the agency's TSCA
Work Plan.
This report addresses the
following:
•	Ensuring the safety of
chemicals.
•	Compliance with the law.
Send all inquiries to our public
affairs office at (202) 566-2391
or visit www.epa.gov/oiq.
EPA's Chemical Data Reporting Rule Largely
Implemented as Intended, but Opportunities
for Improvement Exist
Implementing policies for data quality
checks will help tailor the information
reported by manufacturers and
importers to meet the EPA's needs
and improve its usefulness.
What We Found
As required by the TSCA, the EPA is
using CDR data to help assess the
risks of chemicals in U.S. commerce.
We determined that the EPA is
implementing the risk evaluation
process as outlined in its TSCA Work
Plan to assess chemicals for human health and environmental risks.
In addition, the EPA uses tools such as on-site inspections to monitor companies'
compliance with the CDR Rule, and the agency takes enforcement action when
violations are identified. However, we noted that while the EPA conducts data
quality checks of the chemical information submitted by companies every
4 years, the agency lacks documented policies and procedures that specify how
to select and conduct these data quality checks. Policies and procedures would
help the EPA implement future data quality checks that meet its information
needs, as well as help prevent the possible loss of institutional knowledge during
periods of staff turnover or absence.
We also noted that public stakeholders and EPA employees we interviewed cited
issues regarding accessing and extracting CDR information from the EPA's CDR
database. Our attempt at accessing information from the agency's database also
proved difficult. However, during the course of our audit, the EPA took steps to
help users more easily navigate the data by providing Microsoft Excel files and a
data dictionary. These improvements are intended to enhance the public's ability
to obtain information about chemicals in U.S. commerce.
Recommendation and Planned Agency Corrective Action
We recommend that the Assistant Administrator for Chemical Safety and
Pollution Prevention develop and implement a policy and/or procedures for how
the agency will conduct data quality checks of CDR Rule data submitted by
companies to the EPA.
The Office of Chemical Safety and Pollution Prevention concurred with our
recommendation and provided an acceptable corrective action with a milestone
date. The proposed corrective action, when completed, will meet the intent of the
recommendation.
Listing of OIG reports.

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