Saturday, January 14, 2017

Changes To Toxic Release Inventory Reporting Chemicals In 2017

On November 28, 2016, the USEPA published a final rule that adds a HBCD category to the TRI list of reportable chemicals. The HBCD category includes two CASRNs:
•3194-55-6 (1,2,5,6,9,10-HBCD) and
•25637-99-4 (HBCD).


Since the HBCD category meets the TRI criteria for a persistent bioaccumulative toxic (PBT) chemical, USEPA established a reporting threshold of 100 lbs for the category.


The rule was effective November 30, 2016, and applies to the 2017 reporting year with the first reports due by July 1, 2018.


On November 16, 2016, the USEPA published a proposed rule to add a NPE category, which contains thirteen NPEs, to the TRI list of reportable chemicals. NPEs are nonionic surfactants used in adhesives, wetting agents, emulsifiers, stabilizers, dispersants, defoamers, cleaners, paints, and coatings. If finalized as proposed, facilities required to report NPEs included in the new category would file just one TRI report form for the covered NPEs.

Toxic Release Inventory reports for calendar year 2016 are due by July 1, 2016

Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website




Wednesday, January 11, 2017

Proposed Amendment of TSCA Chemical Data Reporting Rule

EPA intends to establish a Negotiated Rulemaking Committee under the Federal Advisory Committee Act (FACA) and the Negotiated Rulemaking Act (NRA) to negotiate a proposed rule would limit chemical data reporting requirements for manufacturers of certain inorganic byproduct chemical substances.. The objective of the Negotiated Rulemaking Committee will be to negotiate a proposed rule that would limit chemical data reporting requirements under section 8(a) of the Toxic Substances Control Act (TSCA), as amended by the Frank. R. Lautenberg Chemical Safety for the 21st Century Act, for manufacturers of any inorganic byproduct chemical substances, if byproduct chemical substances are subsequently recycled, reused, or reprocessed.


What is the Negotiated Rulemaking Process?

In 1986, EPA created the Inventory Update Reporting (IUR) regulation under TSCA section 8 to collect, every four years, limited information on the manufacture (which includes import) of organic chemical substances listed on the TSCA Inventory, thereby providing more up-to-date production volume information on the chemical substances in U.S. commerce. In 2005, EPA amended the IUR to require the reporting of information on inorganic chemical substances and to collect additional manufacturing, processing, and use information. Manufacturers of inorganic chemical substances first reported under the IUR in 2006. They also reported under the CDR in 2012 and 2016. Specific reporting requirements for these manufacturers were phased in, to allow for the industry to better understand the reporting requirements and for EPA to gain a better understanding of the industry. In recent years, the regulatory requirement to report byproduct chemical substances (and the availability of exemptions from that requirement) has been a frequent topic of discussion.

In 2011, EPA also stated that it would examine CDR information related to byproduct chemical substances to identify whether there are segments of byproduct chemical substance manufacturing for which EPA can determine that there is no need for the CDR information to continue to be collected, either for 2016 or for future reporting cycles. On June 22, 2016, TSCA was amended by the Lautenberg Act. TSCA now includes a requirement that EPA enter into a negotiated rulemaking, pursuant to the NRA, to develop and publish a proposed rule to limit the reporting requirements under TSCA section 8(a), for manufacturers of any inorganic byproduct chemical substances, when such byproduct chemical substances, whether by the byproduct chemical substance manufacturer or by any other person, are subsequently recycled, reused, or reprocessed.

Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs.
For further information contact


Caltha LLP at info@calthacompany.com or Caltha LLP Website



Saturday, January 7, 2017

Overview of EHS Management Systems For The Hazardous Materials Manager - EH&S Compliance Professional

The link below provides training slides from the CHMM Review Course on Environmental Management Systems (EMS) and Health & Safety Management Systems.


Presentation Slides: EHS Management Systems Overview for the Hazardous Materials Professional


Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

New Washington Interim Policy On Handling Pharmaceutical Wastes Classified As Dangerous Waste

Washington Department of Ecology has developed an interim policy for generators of pharmaceutical wastes which could be classified as “dangerous waste” under State rules. The State has enacted this policy pending US EPA finalizing federal rules to streamline handling and disposal of these wastes. Once the EPA rule is finalized, Ecology expects to adopt the federal rule.


What are the generator requirements under the interim Ecology policy?

Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

Sunday, December 25, 2016

Tier II Hazardous Material Reporting in Wisconsin | When Are Tier 2 Reports Due?

EPCRA 302/311/312 reports (“Tier II Reports”) are due on an annual basis to the State and Local Emergency Planning Committee and local emergency response agencies, such as the fire department. The information provided is used in the evident of an emergency, such as a fire, to evaluate potential chemical and other hazards at the property, and to select appropriate protection equipment and fire fighting techniques. EPCRA reporting facilities disclose the types, quantities and locations of hazardous materials. Facilities also provide with Safety Data Sheets for each material.

There are separate reporting requirement for hazardous materials (any material that requires a Safety Data Sheet under OSHA rules) and Extremely Hazardous Substances (EHS) which are a specific chemicals listed by US EPA. A very common example of one such EHS is sulfuric acid.

When are Tier II reports due in Wisconsin?

The Tier 2 report is due March 1 of each year and is based on chemicals stored at your site during the previous calendar year. Reporting can be completed by using the Wisconsin Hazmat Online Planning and Reporting System.

Caltha LLP provides technical support to facilities in Wisconsin that submit reports under EPCRA 311 and EPCRA 312.

Click here for a summary of some recent changes to EPCRA Tier II reporting requirements

For more information or to request a quote go to:
Caltha LLP EH&S Compliance Support Services



Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website



Sunday, December 11, 2016

Environmental Compliance Training, Waste Management Training, SPCC Training

Caltha LLP provides a wide range of training programs to industrial and government sector clients to meet the requirements of State and EPA rules, permits and related spill and emergency preparedness rules. Training can be provided to large or small groups and is provided either in person at your location, or through a live webinar format. For further information and to request a quote, go to Employer's Environmental Health and Safety Training Center.


The training sessions commonly requested include:
  • Hazardous waste management training
  • SPCC annual training
  • Spill response training
  • DOT hazardous material (HazMat) triennial recertification and initial training
  • Facility compliance training overview (covering a wide range of typical facility environmental compliance topics)
  • Internal compliance auditor training
  • Industrial and construction site stormwater discharge permit training
  • Stormwater monitoring training
  • Training for site inspections
Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

Saturday, December 10, 2016

MPCA Delays Enforcement Action On Handling of Hazardous Aerosols & Cylinders

The Minnesota Pollution Control Agency has extended its compliance deadline for one important change to its policies regarding management of spent aerosol cans and gas cylinders that contain hazardous chemicals. Historically, the MPCA had elected not to take enforcement action against hazardous waste generators who empty aerosol cans and cylinders by releasing pressure into the atmosphere, including those who puncture cans with equipment fitted with carbon or other filtration systems to capture vapors. The agency considers this "abandonment" of hazardous waste, which is prohibited.


The MPCA had planned to change its enforcement policy as of January 1, 2017. which would require generators using such equipment to find an alternate means of handling aerosol cans and cylinders. The agency recently announced that it has extended this change to enforcement policy until January 1, 2018, to allow facilities more time to modify their practices, if needed.


Minnesota is one of only a few States that allows aerosol cans and gas cylinders to be handled as though they were universal wastes, although they are technically not regulated as universal wastes under State and Federal rules. MPCA has established some minimum requirements generators must comply with to take advantage of this policy.


Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website