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,
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.
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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.
The 16 chemicals include:
(more…)
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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. 
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.
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