Editor – Environmental Management and Compliance

TRI Reporting for 2014 – What’s New?

The July 1 deadline for Toxic Release Inventory (TRI) reporting again looms! What’s new for your Form R (or Form A) reports?

You can find information on the TRI reporting changes on the EPA website. Notably, you should be aware of the following revisions and updates:

New TRI chemicals: The chemical o-nitrotoluene has been added to the list of chemicals subject to TRI reporting requirements and should be reported for 2014.

New TRI-MEweb features: TRI-MEweb is EPA’s required on-line reporting application. You can now use TRI-MEweb to update facility location and contact information without having to submit a TRI reporting form, or to indicate that you will not be submitting a form for one or more previously reported chemicals or even will not be reporting at all for the current year.

For 2014, the following data entry requirements and options apply:

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OSHA GHS Update – The June 1 Deadline

label example from OSHA Brief 3636

Are you in compliance with the OSHA Hazard Communication Standard, as revised to incorporate the Globally Harmonized System of Classification and Labeling of Chemicals (GHS)?

June 1, 2015, is an important deadline to meet the revised requirements. By this date, if your operation manufacture, import or distribute chemicals, you must:

identify hazards associated with the chemicals you manufacture, import or distribute, using the new “hazard classification” system that replaces the previous hazard determination;
properly label all hazardous chemicals shipped with specified label elements including signal word, pictograms, hazard statements and precautionary statements (see example above);
prepare and distribute with chemical shipments Safety Data Sheets that comply with the new 16-section format (replacing the former “Material Safety Data Sheet” or MSDS).

OSHA has signaled some leniency with regard to enforcement, particularly with respect to downstream manufacturers and distributors that may have difficulty obtaining hazard data on mixture ingredients from upstream suppliers.

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New OSHA Injury Reporting Requirements Are In Effect

As of January 1, 2015, requirements for workplace injury reporting to the Occupational Safety and Health Administration (OSHA) have changed. Employers are now required to report all work-related fatalities within 8 hours and all inpatient hospitalizations, amputations, and losses of an eye within 24 hours of finding out about the incident.

Employers can report these severe incidents to OSHA in one of three ways. You can:

call the nearest OSHA area office during normal business hours,
call the 24-hour OSHA hotline at (800) 321-OSHA (1-800-321-6742), or
report online at www.osha.gov/report_online/. (Note that at the time of this post, the on-line reporting site was not yet up and running.)

Employers under Federal OSHA’s jurisdiction were required to begin reporting by January 1. If your establishment is located in the jurisdiction of a state-run OSHA program, you may want to contact your state agency for the implementation date.

How to Comply with Toxics Release Inventory Reporting Requirements

Are you ready for the July 1 deadline for Toxics Release Inventory (TRI) reporting of your releases, disposals and off-site transfers of listed toxic chemicals? Look HERE for guidance on TRI Form R (and Form A) reporting.

We have put together an informational presentation – as shown in the above screen capture of the title page – to help you and responsible personnel in your organization understand the reporting requirements set forth in the Emergency Planning and Community Right-to-Know Act (EPCRA), which include the annual TRI reports. This presentation is described in greater detail and accessible HERE. Both free PDF download and fully editable Powerpoint presentation (PPT) formats are available.

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As Time Goes By… the Hazardous Waste Biennial Report Comes Due!

Um, yeah, this may not be the best example of drum storage…

Once again, the March 1 deadline looms for large quantity generators of hazardous waste as well as facilities that treated, stored or disposed of hazardous waste on-site to submit their hazardous waste biennial reports to the US Environmental Protection Agency.

If in any month in 2013 your facility

generated more than 1,000 kilograms (2,200 pounds, or about four to five 55-gallon barrels) of RCRA hazardous waste,
generated or accumulated more than 1 kg of acute hazardous waste, or
generated or accumulated more than 100 kg of spill cleanup material contaminated with acute hazardous waste,

then you are a RCRA Large Quantity Generator (LQG) and must complete and file the 2013 Hazardous Waste Report. Hazardous wastes imported to your facility from a foreign country should be included in your generator count.

And if in 2013 your facility treated, stored or disposed of hazardous wastes on-site as a permitted hazardous waste facility, you must complete and file the 2013 report.

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Tier Two. Almost due. So, what’s new?

Changes to Tier Two Hazardous Chemical Inventory reporting requirements are now effective!

On July 13, 2012, EPA published a final rule to revise Tier I and Tier II reporting forms, as well as the Confidential Location Information Sheet. The revisions added some new data elements and revised some existing data elements.

The rule became effective on January 1, 2014. Facilities must comply with the new requirements on the Tier II inventory form for reporting year 2013, which is due by March 1, 2014. (Note that your state may have specific requirements for reporting and submission the Tier II inventory form and/or the state reporting form or format. Contact T. Cozzie Consulting or your state for information on state specific reporting requirements.)

The reporting requirements under the community right-to-know provisions of EPCRA sections 311 and 312 are on-going obligations. These requirements apply to owners and operators of facilities that store hazardous chemicals in quantities at or above reporting thresholds specified in 40 CFR part 370. Under EPCRA section 312, if a hazardous chemical is present at or above the reporting threshold , the facility owner or operator is required to submit an emergency and hazardous chemical inventory form (Tier II or state equivalent, as no states currently accept the shorter Tier 1 form) to the SERC, LEPC and the local fire department by March 1 annually.

Changes to the reporting requirements that take effect for the 2013 reporting year include the following:

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ASTM E1527-13 Standard Recognized for All Appropriate Inquiries

In a December 30, 2013, final action, the Environmental Protection Agency has announced that use by persons performing All Appropriate Inquiries under CERCLA of the recently approved ASTM E1527-13 Standard, “Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process,” is appropriate and acceptable to demonstrate compliance with the AAI Rule (40 CFR Part 312).

To the consternation of many, EPA’s amendment to the AAI Rule to allow use of the E1527-13 Standard did not also delete reference to the ASTM E1527-05 Standard, which E1527-13 updates, modifies and replaces. EPA indicated in publication of the December 30 rule amendment that a future rulemaking would propose removal of the E1527-05 reference from the AAI Rule, subject to public comment and the rigors of the rulemaking process. In the meantime, All Appropriate Inquiries under CERCLA can be satisfied by conformance with procedures specified by the ASTM E1527-13 or ASTM E1527-05 “Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process”; similar procedures set forth in the ASTM E2247-08 “Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process for Forestland or Rural Property” where applicable; or the standards and practices set forth at 40 CFR Part 312 itself.

We will shortly update our All Appropriate Inquiries page to review the changes made to the E1527-13 Standard and AAI Rule. If you have questions in the meantime or need assistance with Environmental Due Diligence services, please contact T. Cozzie Consulting Inc.

HazCom Training Deadline Looms…

As a reminder, OSHA requires that employees be trained on the container labeling and safety data sheet requirements of the revised hazard communication standard by December 1, 2013. If you haven’t yet provided this training and desire assistance with it, T. Cozzie Consulting has put together a presentation (Powerpoint slides and PDF document) that details the required information.

For more information and to purchase this training presentation, go to www.tcozzie.com/products/ghs2013/.

A few screen shots from this presentation follow:
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