Chemical Inventory

Pursuant to a congressional request, GAO reviewed the Environmental Protection Agency's (EPA) proposed approach for updating its chemical substance inventory as authorized by the Toxic Substances Control Act.

GAO found that EPA proposed to exempt: (1) four categories of chemicals from the inventory update in an effort to focus the inventory on the chemicals for which it is most likely to need information; (2) large manufacturers from reporting on any chemical manufactured in quantities less than 10,000 pounds annually; and (3) small manufacturers, which are generally exempt from most reporting requirements under the act. In addition, EPA plans to add an exemption override to the final rule that will require manufacturers to report on certain chemicals that have been of regulatory concern, even if those chemicals fall into one of the exempted categories. Although many of the users interviewed agreed with the proposed exemptions, some raised concerns as to whether chemicals that have been designated as hazardous or will be designated as acutely toxic air pollutants should be exempt from the inventory update. EPA officials stated that it would be better for EPA to use a separate data-gathering rule to obtain all necessary information on those hazardous chemicals. However, EPA has not decided whether or how to gather these data. GAO believes that: (1) the update would provide an opportunity to obtain information on those substances that EPA has designated or plans to designate as hazardous; and (2) the inventory can serve as a reference for identifying the production location for chemicals which are currently exempt from the inventory update that become involved in emergency or accident situations.