Toxic Substances Control Act (TSCA) Introduce yourself. Explain the roster procedure to participants and pass out roster for them to sign. Discuss the emergency evacuation procedure for the facility. 1

GOAL: Ensure employees recognize their responsibilities under the Toxic Substance Control Act. OBJECTIVE: To set the stage for learning by letting participants know exactly what they are expected to know and do following the training. HIGHLIGHT:

Objectives: Upon completion of this course the participant will be able to: Describe the importance of allegations in identifying and eliminating adverse effects to human health or the environment. Define company and individual responsibilities and liabilities under TSCA 8(c) and 8(e). Define how to report, what to report and when to report spills or releases. OBJECTIVE: To set the stage for learning by letting participants know exactly what they are expected to know and do following the training. HIGHLIGHT:

What is TSCA ? Enacted in 1976 by the Environmental Protection Agency (EPA) to regulate chemical substances. Developed as a result of public demand to stop/control pollution. Two sections of the TSCA Act have a direct bearing on us. Section 8(c) Section 8(e) OBJECTIVE: To discuss the purpose and structure of the TSCA Act. HIGHLIGHT: - The EPA created a set of federal regulations designed to regulate production, work with, and disposal of toxic substances.

Section 8 (c) Records of significant adverse reactions Employers must maintain records of an allegation that a chemical substance has caused a significant adverse reaction to human health or the environment. OBJECTIVE: To discuss the contents of Section 8(c ). HIGHLIGHT: - Allegations may be made by any person. - An allegation does not require substantiation or proof to be subject to TSCA review. It is not more than a suspicion that an adverse reaction is linked to a particular substance, mixture or process. - Significant adverse reactions are reactions that may indicate a substantial impairment of normal activities or long lasting or irreversible damage to health or the environment.

Section 8 (e) Notification of Substantial Risk Requires that the EPA be notified of information indicating that a chemical substance or mixture may cause a substantial risk of injury to health or the environment. OBJECTIVE: To discuss the contents of Section 8(e). HIGHLIGHT: - Substantial effects means that the substance in question could have serious adverse effects on humans, such as cancer, birth effects or death, or present a serious threat to plants, animals or other living organisms. - Notifiable incidents under Section 8(e) are generally based on controlled studies or reports that strongly implicate a specific chemical or product manufactured and distributed by a company. - An 8(c) allegation could trigger an 8(e) reporting requirement. - Incidents of environmental contamination may need to be reported under TSCA 8(e).

Allegation No more than a suspicion that an adverse reaction is linked to a particular substance, mixture or process. Allegations may be made by: Company/contract Employees Customers/Consumers Surrounding neighbors Does not require proof to be subject to review. OBJECTIVE: Section 8(c) outlines the criteria for allegations and lists who may make such allegations. Cover that even a suspicion of an adverse reaction can constitute grounds for a report. HIGHLIGHT: An 8(c) allegation could trigger an 8(e) reporting requirement. - Incidents of environmental contamination may need to be reported under TSCA 8(e).

Responsibilities and Liabilities Compliance with TSCA is the responsibility of the individual employee and the employer. Failure to comply: fine of $25,000.00 per day up to one year in prison, or both Discharge of obligation: immediately reporting to your supervisor any adverse reactions or health effects that have come to your attention. OBJECTIVE: To discuss individual and company obligations under the TSCA Act. HIGHLIGHT: - Failure to comply could result in civil penalties of up to $25,000 per day per violation and possibly criminal prosecution. - If convicted, punishment could carry an additional fine of up to $25,000 per day per violation or up to one year in prison, or both.

Reporting Notify your supervisor. Use the TSCA report and evaluation form. An employee has the option of reporting directly to the EPA. Spills or releases of chemical substances which seriously threaten human health or the environment must be reported to the EPA immediately. OBJECTIVE: To discuss reporting procedures. HIGHLIGHT:

Summary Allegations do not have to be proven. Effects must be previously unknown. Substantial risk means: Serious adverse effects on humans, such as cancer, birth defects, death or present a serious threat to plants, animals or other living organisms. Report allegations to your supervisor. Summarize main teaching points, entertain questions and administer the quiz and review.