Respondents failed to submit a Form U for four chemical substances 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 infomration as required by TSCA or a rule thereunder.
In addition, beginning on March 20, 2007, and continuing to an including May 24, 2010, Respondent imported a chemical substance, Titanium (CASN 7440-32-6) on one hundred and twenty-six (126) different occasions and failed to submit the one hundred and twenty-six (126) certifications as required by 19 C.F.R. 12.121. Respondents failure to comply with the required certification requirements of 19 C.F.R. 12.121, promulgated to implement section 13 TSCA, 15 U.S.C. 2612, violated section 15(3)(b) of TSCA, 15 U.S.C. 2614(3)(B).