Environmental Management and Compliance News, Tips and Tools

May 9, 2012

Are you ready for TRI Form R Reporting?

image: chemical storage area

Yep, it’s that time of year again. Toxic Release Inventory (TRI) Form R (or Form A, under certain conditions) reports for 2011 are due to the US Environmental Protection Agency by July 1. EPA prefers, of course, that you file electronically, and has proposed a rule requiring electronic filing – but the rule, if finalized, won’t take effect until next year (for the 2012 reporting year). Look to our TRI reporting page to determine if your facility must prepare and submit Form R or Form A reports for calendar year 2011.

Some rule changes will affect reporting requirements for this year:
(more…)

Filed under: Compliance,EPCRA,Reporting,Rules and Regulations,Toxic Chemicals,Toxics Release Inventory Form R,USEPA — TCozzie @ 10:38 pm

April 4, 2012

EPA revises TPQ… meaning what, now?

On March 22, the Environmental Protection Agency quietly revised 40 CFR Part 355, with respect to how the threshold planning quantities (TPQs) should be derived for Extremely Hazardous Substances (EHSs) that are non-reactive solids in solution. Effective April 23, 2012, a facility should first multiply the weight of the solid EHS in solution by 0.2 and then compare that quantity to the lower published TPQ. Formerly, 100% of the weight of the solid in solution would be compared to the TPQ.

In a regulatory landscape littered with TPQs, RQs (reportable quantities), TRI Thresholds and Clean Air Act TQs (threshold quantities) applied to EHSs, CERCLA Hazardous Substances, Section 313 Toxic Chemicals and Section 112(r) Substances for Accidental Release Prevention among other chemical lists, what is the actual impact of this change? Where do we find regulatory relief?
(more…)

Filed under: Compliance,EPCRA,Reporting,Rules and Regulations,Tier Two Hazardous Chemical Inventory,USEPA — TCozzie @ 6:34 pm

February 8, 2012

Deadlines and Commitments – February 2012

image: time, gentlemen!
Important compliance deadlines are fast approaching:

March 1 – Hazardous Chemical Inventory reports (“Tier Two reports”) are due for all facilities that store more than 10,000 pounds of hazardous chemicals (loosely defined as any chemical for which a Material Safety Data Sheet is required) or more than the threshold planning quantity of an Extremely Hazardous Substance (EHS).
Reporting requirements, forms and procedures are found at this EPA site.
In Florida, visit the State Emergency Response Commission site.
In Georgia, visit this Environmental Protection Division page.

Also by March 1 – The 2011 Biennial Hazardous Waste Report is due for any large quantity generator of hazardous waste or hazardous waste treatment, storage, disposal or recycling facility. Visit the EPA Hazardous Waste reporting site for forms and instructions.

April 1 – Coming up in Florida, Annual Air Permit Operating Reports will be due. Reporting information can be found at the Department of Environmental Protection website.

For further information and assistance, you can also contact us, of course.

Filed under: Compliance,EPCRA,Florida,Hazardous Waste,RCRA,Reporting,Tier Two Hazardous Chemical Inventory,USEPA — admin @ 11:37 am

August 25, 2011

New chemical data reporting requirements take effect…

Hazardous Materials Inventory System labelThe US Environmental Protection Agency (EPA) wants more information on commercial chemicals from chemical manufacturers.  Published on August 16, 2011, the EPA’s new Chemical Data Reporting rule (CDR) requires more frequent reporting of critical information on a larger number of chemicals and requires the submission of new and updated information regarding:

  • potential chemical exposures,
  • current production volume,
  • manufacturing site-related data, and
  • processing and use.

The rule limits opportunities for confidentiality claims.  It also requires that the information be submitted via the Internet, using EPA’s electronic reporting tool, e-CDRweb (which will be accessible through the EPA Central Data Exchange, or CDX). The new reporting requirements will take effect in the next data submission period, from February 1 to June 30, 2012.

Get more information and reporting instructions here (http://www.epa.gov/iur/pubs/guidance/aboutsub.html).

Filed under: Compliance,Reporting,Rules and Regulations,Toxic Chemicals,Uncategorized,USEPA — TCozzie @ 4:19 pm

June 12, 2011

Reminder: Deadline for 2010 TRI Form R Reporting is Near!

It’s like this happens every year…

If you have not completed your Toxic Chemical Release Inventory (TRI) reports yet, note that they are due by July 1.

For additional information, refer to our TRI reporting guidance pages:

The US Environmental Protection Agency site for Toxic Release Inventory Reporting is www.epa.gov/tri/.

Of course, feel free to contact T. Cozzie Consulting (but soon!) if you need additional information or assistance.

Filed under: Compliance,EPCRA,Reporting,Rules and Regulations,Toxics Release Inventory Form R,USEPA — admin @ 3:49 pm

June 17, 2010

Reminder – TRI Reports due in two weeks!

If you have not completed your Toxic Chemical Release Inventory (TRI) reports yet, note that they are due by July 1.

For additional information, refer to our TRI reporting guidance pages:

Of course, feel free to contact T. Cozzie Consulting (but soon!) if you need additional information or assistance.

Filed under: Compliance,Reporting,Toxics Release Inventory Form R — TCozzie @ 4:57 pm

May 11, 2010

Compliance Alert: Deadline for Toxic Chemical Release Inventory Form R report is July 1

Toxic Chemical Release Inventory (TRI) Form R or Form A reports are due by July 1! If your facility:

  • has 10 or more employees;
  • is included among certain covered industrial categories, including manufacturers that correspond to SIC Codes 20 through 39; some mining operations; utilities that burn coal or oil for commercial electrical generation; chemical wholesalers; petroleum bulk storage terminals; and waste treatment, disposal and recovery facilities; and
  • manufactured, imported, processed or otherwise used listed toxic chemicals above threshold reporting quantities,

(link to EPA reporting page)
Then you are likely required to report your releases and off-site transfers of the toxic chemicals.  More information on these requirements is linked at www.tcozzie.com/compliance/tri-2009.htm.  You can visit the Environmental Protection Agency’s TRI reporting materials page by clicking on the image at right.

Does your facility need to comply? Are you ready to meet this requirement? As always, feel free to contact T. Cozzie Consulting for further information or assistance.

Filed under: Compliance,EPCRA,Reporting,Rules and Regulations,Toxic Chemicals,Toxics Release Inventory Form R,USEPA — TCozzie @ 9:58 am

April 20, 2010

EPA proposes expansion of mandatory greenhouse gases reporting requirements

In three four (!) separate notices published in the April 12 Federal Register, the US Environmental Protection Agency has proposed to expand the information required under the Mandatory Reporting of Greenhouse Gases Rule.  The additional information to be required includes…

  • reporting of emissions of fluorinated greenhouse gases (GHGs) from certain sources, such as electronics manufacturing, production of fluorinated gases, and use of electrical transmission and distribution equipment, as well as manufacture or refurbishment of electrical equipment;
  • reporting on carbon dioxide (CO2) injection and geologic sequestration;
  • emissions reporting from the following industry segments:  petroleum and natural gas production, natural gas processing, natural gas transmission compressor stations, underground natural gas storage, liquefied natural gas (LNG) storage, LNG import and export terminals and distribution; and
  • for reporters subject to the rule to provide:  the name, address, and ownership status of their US parent company; their primary and all other applicable North American Industry Classification System (NAICS) codes; and an indication of whether or not any of their reported emissions are from a cogeneration unit.

For more information on the proposed rules and how to comment, visit the EPA’s GHG reporting web page.

Filed under: Air Pollution,Compliance,Greenhouse Gases,Reporting,Rules and Regulations,USEPA — TCozzie @ 5:50 pm

April 6, 2010

EPA proposes adding 16 chemicals to Toxic Release Inventory reporting rule

On April 6, EPA proposed to add sixteen (16) chemicals to the list of toxic chemicals subject to reporting under section 313 of the Emergency Planning and Community Right-to-Know Act (your Form R or Form A submissions due each July 1). These sixteen chemicals have been classified by the National Toxicology Program as “reasonably anticipated to be a human carcinogen.” Based on its review of available production and use information, EPA has concluded that these sixteen chemicals are manufactured, processed, or otherwise used in quantities that would exceed the EPCRA section 313 reporting thresholds.
image: hazardous substance warning label
The 16 chemicals include:

(more…)

Filed under: EPCRA,Reporting,Rules and Regulations,Toxic Chemicals,Toxics Release Inventory Form R,USEPA — TCozzie @ 2:25 pm

March 26, 2010

Compliance Alert: Florida air permit annual operating reports are due April 1

We just wrapped up preparation and delivery of several air permit Annual Operating Reports for Florida clients, using the state Department of Environmental Protection’s electronic annual operating report software.  If you are an air permit holder subject to this annual reporting requirement, be aware that submission of the annual operating report is due by April 1.  That’s right, the due date is less than a week away!

If you haven’t done so already, download the software and get started now.  Or contact us right away for assistance with preparation of your report.

Filed under: Air Pollution,Compliance,Florida,Reporting — TCozzie @ 12:29 pm
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