Author: tcozzie

What’s New for 2016 TRI Reporting (and a gentle reminder)

The July 1 due date for Toxic Release Inventory (TRI) reporting (i.e., Form R or Form A reports) is again coming up. A few notable changes to reporting requirements affect 2016 submissions:

  • A new chemical has been added to the TRI reporting list for 2016. In November 2015, EPA added 1-bromopropane, used primarily in various industries as a solvent/degreaser. If the reporting thresholds for manufacture, processing or other use of this chemical were exceeded at your facility in 2016, it must be reported.
  • The TRI-ME web application for report preparation and submission has been updated! We have done a run-through of the revised program and found that, just as EPA claims, the “modernized” version of TRI-ME web does make the process more streamlined and simplified. It just looks better, too.

Remember, you must use the TRI-ME web application (accessed through EPA’s Central Data Exchange at cdx.epa.gov) to submit and certify annual TRI reports. If you’re unfamiliar with the application or need help with any aspect of TRI reporting, please contact T. Cozzie Consulting for assistance.

Generator Improvement Rule: Relief for Hazardous Waste Generators?

Well, certainly some relief for the very little ones – what we used to call “conditionally exempt small quantity generators” – henceforth (or beginning on the effective date of the Environmental Protection Agency’s Hazardous Waste Generator Improvements Rule, published in the Federal Register on November 28, 2016) to be known as Very Small Quantity Generators or VSQGs.

The Hazardous Waste Generator Improvement Rule, which EPA describes as the culmination of a review that began over 10 years ago, is meant to “improve program effectiveness, reduce compliance costs, and foster an improved relationship with states and the regulated communities.”

The final rule contains a number of provisions which EPA identifies as “more stringent”, including marking and labeling of wastes to identify hazards, Small Quantity Generator recertification, notification of facility closure and requirement that a Large Quantity Generator close as a landfill if it cannot meet closure standards, extending biennial reporting for the whole year rather than just months when the facility was an LQG, biennial reporting for recyclers even when they do not store waste prior to recycling, and a requirement that LQGs provide a “quick reference guide” for distribution with their Contingency Plans. “More stringent” standards must be adopted by states that manage their own hazardous waste programs.

The rule also contains “less stringent” provisions, of a kind that may elicit appreciative nods from industries. These address (1) consolidation of VSQG waste at a LQG facility under the same ownership; (2) allowing VSQGs and SQGs to retain their classification in the event that “episodic generation” would bump them up to a higher generator category; and (3) waiver from the requirement that ignitable and reactive wastes be stored at least 50 feet from a facility’s property line under certain circumstances.

Continue reading “Generator Improvement Rule: Relief for Hazardous Waste Generators?”

Alert! TSCA Chemical Data Reporting Deadline Nears

>> UPDATE: EPA has announced that the deadline for Chemical Data Reporting submissions has been extended to October 31.

The period for submission of 2016 reports required under the Toxic Substances Control Act (TSCA) Chemical Data Reporting rule ends on September 30th. The reporting requirement applies to any person that manufactured or imported, in any year from 2012 to 2015, listed chemicals in more than threshold amounts (generally 25,000 pounds, though a lower threshold of 2,500 lbs has been set for toxic chemicals that are subject to certain TSCA actions), unless exempted as a small manufacturer. Some 80,000 chemicals are on the TSCA list.

A sample reporting form (“Form U”) and instructions to help guide you through the reporting process can be found at the EPA Chemical Data Reporting website. The reports must be submitted online, using the EPA’s Central Data Exchange system (cdx.epa.gov). You will need to add the program area CSPP: Submissions for Chemical Safety and Pesticide Programs to your profile on CDX to activate this reporting option, if you haven’t already done so.

If you have questions about the Chemical Data Reporting requirements or submission process, please contact T. Cozzie Consulting for immediate assistance.