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ACROSS THE POND Assessing REACH's First Big Impact on U.S. ...

ACROSS THE POND Assessing REACH's First Big Impact on U.S. ...

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ENVIRONMENTAL DEFENSE FUNDIUR data: How much does EPAknow and what isn’t t it telling us?• All data required under IUR is eligiblefor CBI status.• EPA reports certain data <strong>on</strong>ly in rangesor aggregates across all submitters.• Some data need not be submitted if not“reas<strong>on</strong>ably ascertainable” or “readilyobtainable” by producer.• No reporting obligati<strong>on</strong> <strong>on</strong> downstreamusers.24

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