FHUS violated the Toxic Substances Control Act (TSCA) as follows:
In letters dated January 5, 2011 and February 15, 2011, a representative of FHUS admitted violations of section 12(b) of TSCA. Specifically, FHUS failed to notify EPA in writing of its intent to export on forty-eight (48) occasions five (5) chemical substances subject to section 4 and 5 of TSCA. In addition, FHUS violated TSCA section 5 manufacturing and processsing notices requirements at 40 C.F.R. Part 720 for a chemical substance that was manufacutred once on a trial basis for one of its customers.