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:
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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?
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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

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

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 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:

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

February 15, 2010

Compliance Alert: Deadline for Tier Two Reporting is March 1

March 1 is the deadline for covered facilities to file Tier II Hazardous Chemical Inventory Reports.  Under Section 312 of the Emergency Planning and Community Right-to-Know Act (EPCRA), this requirement applies to your  facility if at any time you have more than threshold amounts of hazardous substances on your site. right-to-know center - hazardous chemicals inventory reporting The threshold quantities are the lower of either 500 pounds or the threshold planning quantity for extremely hazardous substances, and 10,000 pounds for other hazardous substances (subject to certain exemptions that apply for hazardous wastes, tobacco, wood products, manufactured “articles,” food, drugs, cosmetics, alcohol and agricultural products, and higher thresholds for fuel storage at retail gas stations).

The list of extremely hazardous substances and their threshold planning quantities can be found at www.epa.gov/emergencies/docs/chem/title3_Oct_2006.pdf.  Other “hazardous substances” include materials that are hazardous as defined in the OSHA Hazard Communication Standard (29 CFR 1910.1200); generally, any material for which a Material Safety Data Sheet (MSDS) is required.

Tier Two reports should be provided to the State Emergency Response Commission, Local Emergency Planning Council and local fire department.

EPA offers a software program, “Tier2 Submit,” to facilitate preparation and submittal of Tier Two reports.  Note, however, that many States may require additional information or alternative reporting formats, as well as payments of associated fees.  Visit www.epa.gov/emergencies/content/epcra/tier2.htm for further information, including access to the Tier2 Submit software and links to State requirements, or contact us for assistance with preparation of your Tier Two reports.

Filed under: Compliance,EPCRA,Reporting,Rules and Regulations,Tier Two Hazardous Chemical Inventory — TCozzie @ 6:45 pm