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Do contractors, consultants and independent laboratories have a TSCA §8(e) reporting responsibility?

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Do contractors, consultants and independent laboratories have a TSCA §8(e) reporting responsibility?

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A.7. No. If they do not manufacture, process or distribute in commerce TSCA chemical substances or mixtures, they do not have a TSCA §8(e) reporting responsibility. Rather, their client manufacturers, processors and distributors are responsible for reporting such information.

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