Action Compliance

Product Stewardship, Product Safety and Compliance Departments are charged with the task of obtaining and supplying the proper credentials for product to move safely, quickly and legally from the manufacturing site to the customer's site. This task requires several operations within a business to move pro-actively and re-actively. The forte of Dr. Joseph Kostusyk, founder and principal of Action Compliance, LLC, is the development of processes, staff and product credentials to move product domestically, globally and on time.

Contact Dr. Joseph Kostusyk at 207-223-5158 or via e-mail at actioncompliance@aim.com to discuss how he can assist you in meeting your regulatory compliance demands.

Who we are

Most companies have Product Stewardship or Responsible Care programs that cover chemical compliance issues. However, they may not always have the staff or competencies to achieve compliance in a timely manner. Joseph Kostusyk, Ph.D., is a Senior Regulatory Compliance Specialist who will work within your organizaton to bring your products into the global marketplace. His expertise is in:

-- Document preparation (new chemicals notifications, registrations and Chemical Inventory Searches, and bona fide inquiries) for products that are marketed in the USA, Canada, European Union, Japan, Korea, China, Australia, New Zealand and the Philippines.
-- The technical aspects of complying with the Toxic Substances Control Act (TSCA), including filing new chemical notifications and polymer exemptions with the Environmental Protection Agency (EPA).
-- In depth TSCA audits and the application of the EPA Self Audit Policy. Dr. Kostusyk will conduct TSCA due diligence audits for clients involved with mergers, acquisitions and divestitures.
-- Industry-Government Advocacy. He has been active in the American Chemistry Council as an international advocate in several international Industry-Government forums. He was a representative for the OECD New Chemicals Task Force and is a strong supporter of the “Parallel Process” for notifying new chemicals globally.

What we do best

-- PMNs (Premanufaturing Notifications) for the USA, Canada, Australia, European Union, Korea, Japan, China, Australia and New Zealand.
-- PMPINs for the Philippines
-- SNIF for the European Union nominations to ELINCS
-- Chemical Inventory Searches for TSCA, DSL, EINECS /ELINCS/ NLP, MITI, KCL, PICCS, AICS, China
-- Audits for TSCA (especially TSCA Sections 4, 5, 6, 8a-e, 11, 12, 13, 14, 15, 16)
-- Teaching, guidance and coaching of staff to “get up to speed” in areas of concern and interest. We can develop and assist in implementing a written compliance program for your company.

Some things we do not do

We do not write product MSDSs and Labels. We can evaluate MSDSs in light of the data in your possession. We feel that a company should have an MSDS system that is data based, generating labels based on the MSDS data and linked to the company's operating system. In light of the European REACH legislation and other international developments, we encourage companies to begin learning the Global Harmonized System for hazard communication. We have worked with several MSDS systems and can recommend some good products and approaches to writing MSDSs.
We do not register products for FIFRA and FDA. We can refer you to some technical experts and law firms that service those areas.