EPA TSCA Management System and Audit
The Toxic Substances Control Act of 1976 provides US EPA with authority to require reporting, record-keeping and testing requirements, and restrictions relating to chemical substances and/or mixtures. TSCA places responsibilities on the Company and its employees and the penalties for non-compliance can include both direct and punitive fines, and imprisonment.
The management system is an ISO 9001 based system of procedures that can be adapted to fit the Company organization and its commercial activities. The management system formally establishes the commitment of the Company seniors to compliance with TSCA regulations, the accountabilities and processes whereby the Company and its employees comply with the specific regulatory requirements.As with all ISO systems the management system includes a process of continual improvement through an audit, checklists and auditor training/certification, systems for the retention of objective evidence of compliance.
This management system has proven effective for over 10 years in a major chemical company within the US and has successfully been used to mitigate penalties in cases of TSCA infringements that were self-declared to EPA. The commitment by senior management to implement a quality based TSCA management system has the potential to mitigate punitive fines as part of a consent agreement.
The Consultancy service includes the following stages:
- Working with individuals identified by the Company to scope the business organization and activities, and produce a detailed plan for the tailoring of the system to meet the needs of the Company.
- Development and Implementation of the TSCA Management System including the adaption of pre-formed procedures to identify Company specific roles and systems.
- Training of internal auditors, external audit and the organization of verification audits by 3rd party recognized TSCA experts.