A minimum data set: Why, what, how much and when?

. Finally, chemicals that are prioritized will be subject to safety determinations sooner, so their MDSs will be needed to be developed and submitted sooner than those for other chemicals.

We propose, therefore:

• Companies should be required to submit information they already possess about a chemical’s identity, properties, production, use, hazards and exposure potential within one year of enactment.
• Companies should update such information at a minimum every three years, and immediately whenever significant new information becomes available or significant changes in a chemical’s production or use occur.
• EPA should develop and publish the MDS requirements within one year of enactment.
• MDSs for all new chemicals should be submitted at the time companies submit notices of intent to manufacture them. (A transition for new chemicals may be needed during the period between enactment of legislation and EPA’s issuance of the details of the MDS).
• MDSs for all existing chemicals should be submitted within either:
  • five years of enactment, or
  • for priority chemicals, 18 months after they are so identified,

whichever comes first.

• If significant time has passed between initial submission of the MDS for a chemical and when it comes up for its safety determination, companies should have an opportunity and mandate to update their MDSs, so that the most current information is available to EPA.