Bethlehem Apparatus violated the reporting requirements of section 8(a) of TSCA, 15, U.S.C. 2607(a)(Reporting and Retention of Information), and the Inventory Updated Reporting Rule.
Respondent failed to submit a Form U for a chemical substance by March 23, 2007 as required, thereby constituting a violation by failing to submit a report, notice or other information as required by 40 C.F.R. 710.53. Pursuant to section 15(3)(B) of TSCA, 15 U.S.C. 2614(3)(B), it is unlawful for any person to fail or refuse to submit reports, notices, or other informatin as required by TSCA or a rule thereunder.
In addition, Respondent exported a chemical substance to six different countries on six dates without notification as required under TSCA 12(b) and failure to comply with the required certification requirements of 19 C.F.R. 12.121, promulgated to implement section 13 of TSCA, 15 U.S.C. 2612, violates section 15(3)(B) of TSCA, 15 U.S.C. 2614(3)(B)