Recordkeeping (TSCA PBT)

Five-year retention for DecaBDE and PIP (3:1) records (increased from three years by 2024 revision). Three-year retention for 2,4,6-TTBP. Records include business documents, exposure monitoring, downstream notifications, and exclusion documentation. Must be available to EPA upon request.

40 CFR §§ 751.405, 751.407, 751.409; EPA Final Rule (November 2024).

Five-year recordkeeping is baseline. Retain: purchase/sales records, supplier declarations, test reports, SDS copies, exposure monitoring data, and exclusion documentation. The 2024 revision removed the 30-day response requirement.

A distributor maintains five years of records: supplier certificates, updated SDS, invoices, and EPA correspondence.