Josh Hosen โข Nov 08, 2018
The EPA has issued a draft proposed rule with technical amendments to TSCA Title VI to make it easier for companies to demonstrate that they meet the EPA standard. HPVA Laboratoriesยฎ (soon to become Capital Testingยฎ) has been a driving force for the proposed changes. These changes include:Removing annual correlations between a third-party certifier’s chamber and each mill’s quality control chamberAllowing equivalence on similar size or model chambers at the third-party certifier and millAveraging emission test results from quarterly testingEstablishing testing emission rangesAllowing equivalence if the mill uses the third-party certifier to conduct all testsUpdating correlational coefficients and R-value alternativesUpdating the notice of exceeding the quality control limitUpdating NAF and ULEF exemption testing requirementsUpdating to the ISO 17025-2017 and 17011-2017 voluntary consensus standardChanging the text in non-complying lot provisionsClarifying that labels on compliant products are required at point of entry in the U.S.Clarifying the June 1, 2018 manufactured-by date, following the court ruling in 2017Comments are due no later than December 3. For more information:Email us or call Josh Hosen at 703-435-2900 ext. 112 or Brian Sause at ext. 127Read the HPVA Laboratoriesยฎ request for changesSee the EPA’s proposed rule |
