Applicability of the Toxic Substances Control Act to Shipyard Owners and Operators
COLLIER SHANNON RILL AND SCOTT PLLC WASHINGTON DC
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Pursuant to an agreement with the National Shipbuilding and Research Program NSRP, we have conducted research to determine the applicability of the Toxic Substances Control Act TSCA or the Act, 15 U.S.C. 2601 et seq. to shipyard owners and operators hereinafter referred to collectively as shipyard operators. Concern over the applicability of TSCA has arisen because shipyard operators routinely engage in activities that could be construed as processing under TSCA, such as the mixing for application on commercial or Navy ships of epoxy paints, formaldehyde glues, foam-in-place resins, etc. In some instances, chemical substance also may be mixed with rubber compounds or sand to create molds used in forming parts for ships. Shipyard operators also may recycle solvents for re-use at the shipyard, thus producing a distilled or blended solvent.
- Marine Engineering