On April 27, the Environmental Protection Agency issued a final rule revoking the provisions of the Toxics Release Inventory Burden Reduction Rule (December 2006) that expanded eligibility for reporting of chemicals using the Form A certification statement rather than the more detailed Form R report.
The latest ruling returns Form A reporting eligibility to previous levels: Form R must be used for reporting persistent, bioaccumulative and toxic (PBT) chemicals, such as certain pesticides, polycyclic aromatic compounds, lead, mercury, PCBs and dioxins. For non-PBT chemicals, the Form A certification statement can be used if no more than 1 million pounds of the chemical are manufactured, processed or otherwise used at the facility and total quantities released, disposed, treated, recycled and transferred do not exceed 500 pounds.
The rule change applies to reports for 2008, due by July 1. For additional assistance and information, contact us or visit www.tcozzie.com/tri-2008.htm.
