EPCRA 312 Tier II Reports Due March 1, 2012

EPCRA Tier II Hazardous Chemical Storage Reports are due March 1 for sites subject to hazardous chemical reporting. Under the Federal Emergency Planning and Community Right-to-Know Act (EPCRA), any facility that stores hazardous chemicals can have both one-time and annual reporting, specified in Section 311 and 312 of EPCRA. Under EPCRA, hazardous chemicals are any substances for which a facility must maintain a Material Safety Data Sheet (MSDS) under the OSHA Hazard Communication Standard – if a material has an MSDS, it is considered to be a hazardous chemical under EPCRA. This can include materials which might not immediately be considered “chemicals”, such as batteries, fuels, metals, etc.

EPCRA rules apply to all types of sites, and are not limited to a particular industrial sector – reporting sites can be commercial, institutional, warehousing, retail or any other type of site which could store or use chemicals. Facilities with chemicals in quantities that equal or exceed the thresholds must report. The thresholds can be specific to different types of chemicals and can be as low as 500 pounds for some materials, and as high as 10,000 pounds.

As an overview, to comply with EPCRA hazardous chemical storage reporting requirements, for any hazardous chemical used or stored on-site above threshold amounts, facilities must maintain a MSDS, and submit the MSDSs to their State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC) and local fire department. Over time, if the site recieves revised MSDS, most current MSDS must also be submitted. Facilities must also report an annual inventory of these chemicals by March 1 of each year to their SERC, LEPC and local fire department. Under the Federal rule, facilities could provide a report using either a Tier I or Tier II form. However, in practice most States require the Tier II form be used.

Request information on EPCRA Reporting consultant services

FAQ: How are Tier I and Tier II reports different?

Caltha LLP provides specialized expertise to clients nationwide in the preparation and submittal of chemical storage reports, preparation of Toxic Release Inventory (TRI) reports, and preparing cost-effective EH&S management programs.


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OMB Extends Review of OSHA Globally Harmonized System Rule

The Office of Management & Budget (OMB) has extended its review of the final rule on hazard communication requirements in the workplace, which had been expected to be completed in January 2012. In 2011, the Occupational Health and Safety Administration submitted its final rule which would revise labeling and material safety data sheet requirements to align with the "globally harmonized system" (or GHS) used in many other countries. This final rule must be reviewed and approved by OMB prior to being published in the Federal Register.

For more information on the GHS rule, go to:

Summary of Globally Harmonized System for hazard communication and labeling

Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EH&S compliance procedures, and preparing cost-effective EH&S management programs.

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California DTSC & EPA Sign Cooperative Agreement Under Green Chemistry Initiative

The California Department of Toxic Substances Control (DTSC) and the U.S. Environmental Protection Agency have signed a formal agreement which outlines principles by which DTSC and EPA will cooperate to reduce toxic chemicals in consumer products, create new business opportunities in the emerging safer consumer products economy, and reduce the level of effort required for consumers and businesses to identify the components of the products.

This agreement will allow DTSC and U.S. EPA to minimize duplication of effort and promote consistency in their assessment methodologies. The agreement also creates a partnership between the two agencies and sets up a framework to collaborate on Green Chemistry issues related to California’s “Green Chemistry” program. The U.S. EPA’s Green Chemistry Program supports fundamental research in the area of environmentally benign chemistry as well as a variety of educational activities, international activities, conferences and meetings, and tool development, all through voluntary partnerships with academia, industry, other government agencies and non-government organizations.

DTSC’s informal draft Safer Consumer Products Regulations, scheduled to be finalized in 2012, will require manufacturers of selected products sold in California to identify safer alternatives to a potential range of 3,000 chemicals known to be harmful to public health and the environment. DTSC expects to release its draft Safer Consumer Products Regulations in early 2012 for public comment. The Regulations are a key element of California’s Green Chemistry Initiative signed into law in 2008.

Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EH&S compliance procedures, and preparing cost-effective EH&S management programs.

For further information contact Caltha LLP at

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2010 GHG Reporting Program Summary

The comprehensive greenhouse gas (GHG) data reported directly from large facilities and suppliers in the US are now accessible to the public through EPA’s GHG Reporting Program. The 2010 GHG data includes public information from facilities in nine industry groups that directly emit large quantities of GHGs, as well as suppliers of certain fossil fuels. EPA’s online data publication tool allows users to view and sort GHG data for calendar year 2010 from over 6,700 facilities by facility, location, industrial sector, and the type of GHG emitted. Most reporting entities submitted data for calendar year 2010. However, an additional 12 source categories will begin reporting their 2011 GHG data this year.

In summary, GHG data for direct emitters show that in 2010:

• Power plants were the largest stationary sources of direct emissions with 2,324 million metric tons of carbon dioxide equivalent (mmtCO2e), followed by petroleum refineries with emissions of 183 mmtCO2e.


• CO2 accounted for the largest share of direct GHG emissions with 95 %, followed by methane with 4 %t, and nitrous oxide and fluorinated gases accounting for the remaining 1 %.


• 100 facilities each reported emissions over 7 mmtCO2e, including 96 power plants, two iron and steel mills and two refineries.
  

Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EH&S compliance procedures, and preparing cost-effective EH&S management programs.

For further information contact Caltha LLP at

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2012 TSCA Chemical Data Reporting Consulting Services

Beginning in February 2011, reporting under the new TSCA Chemical Data Reporting (CDR) rule will begin. Between February and June 2011, manufacturers and importers of chemical substances that exceeded reporting thresholds in 2011 will be able to submit CDR data on-line.

For more information and background on the CDR rule, go to:

Regulatory Briefing on New Chemical Data Reporting Rule

In summary, data on TSCA chemicals either manufactured or imported in quantities greater than 25,000 lbs needs to be reported.

Caltha LLP provides expert technical support and consulting services to assist companies across the US in determining if they are subject to the CDR rule, and if so to assist in evaluating manufacturing or import data to determine what chemical substances need to be reported. Caltha can provide hands-on technical services to prepare and submit CDR reports, or can provide ad hoc technical advice to companies or individual facilities as they evaluate their data to determine if reporting is required.

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Summary Of TRI Chemical Release Data For 2010

The U.S. Environmental Protection Agency (EPA) is releasing its annual national analysis of the Toxics Release Inventory (TRI), for reporting year 2010. Total releases including disposals for the latest reporting year, 2010, are higher than the previous two years but lower than 2007 and prior year totals.

The 2010 TRI data show that 3.93 billion pounds of toxic chemicals were released into the environment nationwide, a 16 % increase from 2009. The increase is mainly due to changes in the metal mining sector, which typically involves large facilities handling large volumes of material. In this sector, even a small change in the chemical composition of the ore being mined may lead to big changes in the amount of TRI chemicals reported nationally. Several other sectors also reported increases in toxic releases in 2010, including the chemical and primary metals industries.

Total air releases decreased 6 % compared to 2009, continuing a trend seen over the past several years. Releases into surface water increased 9 % and releases into land increased 28 % compared 2009, again due primarily to the metal mining sector.

TRI data is submitted annually to EPA and states by numerous industry sectors including manufacturing, metal mining, electric utilities, and commercial hazardous waste facilities. Facilities must report their toxic chemical releases to EPA under the federal Emergency Planning and Community Right-to-Know Act (EPCRA) by July 1st of each year. The Pollution Prevention Act of 1990 also requires information on waste management activities related to TRI chemicals.

Caltha LLP provides specialized expertise to clients nationwide in the preparation of TRI reports, developing chemical tracking procedures, and preparing cost-effective EH&S management programs.

For further information contact Caltha LLP at

info@calthacompany.com or Caltha LLP Website