TSCA Advisory 98 - III

The U.S. Environmental Protection Agency has informally announced an extension - until January 31, 1999 - of the deadline for submitting Inventory Update Rule (IUR) reports. The deadline for compliance with this Toxic Substances Control Act reporting rule previously had been December 23, 1998. The contractors who operate EPA's TSCA Hotline have been confirming the extension, and state that a formal announcement in the Federal Register should follow soon.

If you need assistance in filing IURs for 1998, or in determining whether this requirement applies to your company or any of its manufacturing sites or activities, please do not hesitate to call any of the attorneys below, or Technology Sciences Group Inc., our consulting subsidiary. Similarly, if you need IUR forms for 1998 (or 1994), we would be pleased to provide them, in the event you would rather not contact EPA directly.

Finally, we include this important cautionary note: the filing of an IUR report in 1998 may trigger an EPA review of such filings for previous reports in 1994. If you discover in the course of preparing 1998 IUR reports that reports were not filed in 1994, we recommend that you consult with counsel prior to submitting the 1998 report. We have substantial experience with disclosures under the EPA's 1995 Audit and Self-Disclosure Policy, which provides relief from civil penalties for violations that are self-disclosued. If you need assistance in positioning your company to make use of that policy in the event violations of the 1994 reporting requirement are discovered, we would be pleased to help.

For more information, please contact: