Josh Hosen • 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 Laboratories® (soon to become Capital Testing®) 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 Laboratories® request for changesSee the EPA’s proposed rule |
