Ponda did not comply with the following three provision of TSCA 1) the testing requirements of section 4(b) of TSCA, 15 U.S.C. 2603(b), and the Chemical Testing Requirements for High Production Volume Chemicals rule, 40 CFR 799.5085, 2)the reporting requirements of section 8(a) of TSCA, 15 U.S.C. 2607(a), and the Inventory Update Reporting Rule (IUR), 40 C.F.R. 710, and 3) the Chemical Testing Requirement for the Second Group of High Production Volume Chemicals (HPV 2) rule, 40 C.F.R. 799.5087