Author Topic: TSCA (Toxic Substance Control Act) and Importation  (Read 1153 times)

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a3d0a3m

  • Guest
TSCA (Toxic Substance Control Act) and Importation
« on: November 17, 2003, 08:22:00 PM »
Does anyone have any experience with their legal research chemicals being detained by customs awaiting a TSCA certification? What would a bee who is importing these chemicals do (besides flushing all of their lab equipment and chemicals down the toilet before the D-E-A comes knocking) to ensure that there is no legal problem? Aparently the chinese chemical company said that they listed their chemical as a food additive so it would be TSCA exempt... however, are research chems tsca exempt or not?

methyl_ethyl

  • Guest
MSDS
« Reply #1 on: November 17, 2003, 09:41:00 PM »
Check the MSDS of the material you have ordered, it should list if there is an TSCA rating.  If it says there is a TSCA listing, than it is listed, no matter what you are using it for, research or otherwise.  If where you are purchasing the said chemical does not offer a comprehensive MSDS or Cof A, I would advise you to go to one of the major suppliers of  research chemicals and look up your product there.  You should find all of the important information that you need to know  before shipping your "research chemical".  Make sure you have your shit together, and do not give yourself away.  Remember purchasers for large companies are not shy, and do not act like a newbees .  Demand what you want, when you want it, and how, or tell them you will go somewhere else.
      
     For an example: If you were ordering 1,4 butanediol (one of my favorite "research chemicals") , you would find in the body of the MSDS, that it is listed on the TSCA inventory.  Thus no matter what you are using it for, recreational, illegal, gray market, polyester, plasticizer, PVC, Solvent based vinyl primer, or any other imaginative usages, it is listed.  So be prepared to act and behave accordingly.  This is considering the chemical is being shipped properly labeled.  It sounds as if your product is being mislabeled, i.e. shipping 1,4 butanediol labeled as High Fructose Corn Syrup.  

     These are some of topics that your MSDS should cover.......



Section 15 - Regulatory Information

US FEDERAL

TSCA
CAS# 110-63-4 is listed on the TSCA inventory.
Health & Safety Reporting List
None of the chemicals are on the Health & Safety Reporting List.
Chemical Test Rules
None of the chemicals in this product are under a Chemical Test Rule.
Section 12b
None of the chemicals are listed under TSCA Section 12b.
TSCA Significant New Use Rule
None of the chemicals in this material have a SNUR under TSCA.
SARA

CERCLA Hazardous Substances and corresponding RQs
None of the chemicals in this material have an RQ.
SARA Section 302 Extremely Hazardous Substances
None of the chemicals in this product have a TPQ.
Section 313
No chemicals are reportable under Section 313.
Clean Air Act:
This material does not contain any hazardous air pollutants. This material does not contain any Class 1 Ozone depletors. This material does not contain any Class 2 Ozone depletors.
Clean Water Act:
None of the chemicals in this product are listed as Hazardous Substances under the CWA. None of the chemicals in this product are listed as Priority Pollutants under the CWA. None of the chemicals in this product are listed as Toxic Pollutants under the CWA.
OSHA:
None of the chemicals in this product are considered highly hazardous by OSHA.
STATE
CAS# 110-63-4 is not present on state lists from CA, PA, MN, MA, FL, or NJ.
California No Significant Risk Level: None of the chemicals in this product are listed.
European/International Regulations
European Labeling in Accordance with EC Directives
Hazard Symbols:
XN
Risk Phrases:
R 22 Harmful if swallowed.

Safety Phrases:
S 24/25 Avoid contact with skin and eyes.

WGK (Water Danger/Protection)
CAS# 110-63-4: 0
Canada - DSL/NDSL
CAS# 110-63-4 is listed on Canada's DSL List.
Canada - WHMIS
This product has a WHMIS classification of D2B.
Canadian Ingredient Disclosure List

     I would assume all food additives are TSCA exempt for obvious reasons, however research chems are not TSCA exempt.  If your product was labeled as a food additive I doubt there will be any problem.  Unless they detain your package for suspicious reasons, analyse it and then determine that your product falls under TSCA rule.  (which I doubt would happen, but do not take my word for it.....  8) )

good_luck

much_love

methyl_ethyl


a3d0a3m

  • Guest
Uh
« Reply #2 on: November 18, 2003, 12:24:00 AM »
Swim is over his head here... should swim just ignore the request for the TSCA form and allow it to be returned to the shipper? Will there be any repurcussion? Swim doesn't have a DBA or wish to fill out a customs importer ID form or ever think about this ever again. What would happen if swim just stopped responding to fedex?

thallium

  • Guest
...
« Reply #3 on: November 18, 2003, 01:03:00 AM »
At least ask the supplier what they shipped the substance as! The customs might try to delay you because they suspect you are importing a research chemical; without having an actual reason for requesting a TSCA-form.


a3d0a3m

  • Guest
Swim
« Reply #4 on: November 18, 2003, 01:27:00 AM »
Swim received a fax from fedex w/ tsca from and a customs importer id form to be filled out and faxed back. Also enclosed was an invoice declaring the item as "glucono delta lactone, uses: food preservative."

thallium

  • Guest
...
« Reply #5 on: November 18, 2003, 02:16:00 AM »
>Swim received a fax from fedex w/ tsca from and a customs importer id form to be filled out and faxed back. Also enclosed was an invoice declaring the item as "glucono delta lactone, uses: food preservative."

Gluconolactone is a solid used in foods and cosmetics, in cleaning products and when brewing. 

But; it actually appears to be listed in the TSCA inventory... US MSDS here:

http://www.purac.com/documents/products/US-GDL.pdf



Why not try to apply for a TSCA exempt? Just make up a valid excuse; you are making anti-wrinkle cream, brewing beer or perhaps making a new cleaning product..!