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HazCom 2012 Monumental or Manageable? We've Got a Plan!

Posted by Shivi Kakar

Apr 23, 2012 4:31:00 AM

By Paula Kaufmann, CIH

I have seen no less than 20 emails inviting me to webinars that will help me get my house in order for all the changes coming with the OSHA Hazard Communication Standard this year.  From the tone of these emails, it would seem like the sky is falling! You know what?  The sky is not falling … although there is work to be done to implement the changes.



OSHA has a reasonable timeline for compliance and with planning, we can get through this with ease!  Here’s our take on the issue …

On first glance, the changes seem monumental …

    • 90,000 workplaces = the number of sites that produce hazardous chemicals in the US.  HazCom 2012 requires these manufacturers to.


-       Modify the hazard classification for chemicals they produce

-       Create new labels to highlight these hazards

-       Draft and distribute revised Material Safety Data Sheets (now referred to as Safety Data Sheets)

    • 43 million US workers = the number of workers in the 5 million facilities that will be notified of the new physical and health hazard classifications for the chemicals in their workplaces by new labels and Safety Data Sheets communicating these hazards.

    • $201 million a year = the cost OSHA estimates to roll out HazCom 2012 for the entire United States. OSHA lists yearly program element costs as follows:


-       $22.5 million for chemical hazards classification based on the GHS criteria and revising safety data sheets and labels to meet new format and content requirements

    • $24.1 million for printing packaging and labels for hazardous chemicals in color


-       $95.4 million for employee training about the new warning symbols and the revised safety data sheet format under GHS

-       $59 million a year for management to become familiar with the new GHS system and to engage in other management-related activities as may be necessary for industry's adoption of GHS

Let’s look at the actual tasks each organization has to accomplish for compliance:

With a plan … these tasks are quite doable!

    • Chemical Users: Continue to update safety data sheets when new ones become available, provide training on the new label elements and SDS format and update hazard communication programs if new hazards are identified.



    • Chemical Producers: Review hazard information for all chemicals produced or imported, classify chemicals according to the new classification criteria, and update labels and safety data sheets.


OSHA’s HazCom 2012 Compliance Timeline …




















Requirement(s)

Completion Date


    • Training


December 1, 2013


    • Classify of Chemicals

    • Modify Labels

    • Update Safety Data Sheets


June 1, 2015


    • Update alternative workplace labeling system

    • Revise Hazard Communication Program


June 1, 2016

On April 25, Emilcott will be presenting a HazCom 2012 Webinar for anyone interested. Our approach—let’s not try to alarm everyone, but let’s provide a basic understanding of the changes made to the standard and a simple plan of action for employers to meet the regulatory requirements within the specified time frames.  Would you like to join us?

Register here: OSHA HazCom 2012: A Simple Plan for Compliance
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Topics: OSHA, OSHA Compliance, Emilcott, Hazardous Waste Management, HazCom, health and safety, Hazardous Materials, Compliance, OSHA Hazard Communication Standard

2011: A Year In Recap

Posted by Shivi Kakar

Jan 4, 2012 3:29:54 AM

Bringing in the New Year is always an exciting time for everyone. People enjoy setting new goals, looking forward to the journey that the New Year brings and starting that resolution they promise they are going to keep. While the New Year brings many things to look forward to, it also is a time where we look back at the year that has passed and take a moment to reflect on what has happened.

At Emilcott, 2011 was a successful year where we were able to tackle new projects, serve our clients and continue to respond to current industry issues in the environmental, health and safety field. Though we have had many great memories from 2011, we would like to mention some of the things that stood out most in our business for 2011.

Hurricane Irene – the immense and powerful Atlantic hurricane that left a path of destruction and devastation was something that definitely stands out in 2011. We remember this event not only because of the wreckage caused by the storm, but also because of the after effects. The staff at Emilcott recognized the importance of addressing the legacy of water intrusion and the promise of mold after the storm and stressed to clients the importance of “timing” to address how to respond to this problem, as well as the importance of selecting the proper remediation technique along with an EHS mold expert and Emilcott’s mold remediation strategy. (Read more: Hurricane Irene Leaves a Legacy of Water Intrusion and the Promise of Mold)

Energy Sector – Emilcott has been thrilled to be able to participate in many different initiatives within the energy sector.  Regionally important to the growth of our economy, the ongoing infrastructure improvements have given us substantial health and safety support work. In EHSWire during 2011 we addressed many occupational hazards as Occupational Heat-related Illnesses where we went over the symptoms that workers may experience, as well as what should be done if someone does experience these symptoms. Besides dealing with working conditions such as heat, Emilcott also provided information on the truths about occupational slips, trips and falls which ended up costing American businesses $13.67 billion in workers compensation costs in 2008. Adhering to proper safety protocols and preventing injuries is something that benefits businesses and their workers. OSHA provides a Walking/Working Surfaces – Safety and Health Topic page which provides links to all the applicable standards.

With issues such as heat affecting the health of workers to preventing injuries on job sites, Emilcott has seen our fair share of mishaps. Being able to share our experiences and knowledge with others never gets old. From teaching someone the hazards about working near a crane, or things you should do when working in certain environments, Emilcott has always tried keeping people in the loop. We even have a 10-Hour Construction Industry Outreach Training Course based on the requirements established by OSHA which is a very hands-on and interactive class that we recommend to avoid a future work related issue. (Read more: Work Near a CRANE? Learn the Hazards!)

9/11 Tenth Anniversary – focused the changes that have occurred since 9/11/2001 such as the new precautions that have taken place on the American Chemical Security issue.   The DHS (the Department of Homeland Security) has been increasing their focus on utilities and chemical facilities which may become targets for terrorist activities and the DHS Chemical Facility Anti-Terrorism Standard (CFATS) now requires completing and submitting a Top Screen analysis to the DHS.

The James Zadroga Act , which was authorized to broaden, renew funding and extend benefits to Ground Zero workers whose death was a result of exposure, is of great significance and has put new emphasis on the importance of proper real-time environmental site monitoring. New technologies are available to protect site workers and the public from exposure to hazardous substances such as those from the collapse of the WTC towers. (Read more: 9/11 Tenth Anniversary Focuses on American Chemical Security)

Toxic Substance Control Act (TSCA) – was of major importance not only to Emilcott, but also to facilities who are manufacturers or importers of chemicals in amounts of 25,000 pounds or greater. With so many questions regarding TSCA and the changes, Emilcott decided to put on a free webinar along with posting a number of blogs that answered many of the concerns our clients had. Emilcott was able to use its expertise and help many clients with TSCA compliance questions and concerns regarding the developments of IUR reporting and reporting obligations in 2011 for the calendar year 2010. (Read more: August 2011 Update on the TSCA IUR-now-CDR Rule)

Though Emilcott has had many remarkable memories of 2011, we felt these 4 really left an impression on our business. Emilcott is privileged to know that we were able to assist our clients in many different businesses not only in 2011, but throughout our history. Emilcott looks forward to a productive 2012 and we are excited to see what this year has in store for us.

Do you have any environmental, health or safety concerns for 2012? If so, please share them with us below!
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Topics: OSHA, Emilcott, health and safety, Hazardous Materials, worker safety, Occupational Health, Occupational Safety, TSCA, Toxic Substance Control Act, Uncategorized, Mold, CFATS

Hazardous Waste How-To for Manufacturers, Laboratories and other General Industry Companies

Posted by Shivi Kakar

Mar 14, 2011 7:27:43 AM



Carrie Bettinger, CHMM, CSP

As a Certified Hazardous Materials Manager (CHMM) and a Certified Safety Professional (CSP) I often make recommendations to our “General Industry” clients in an effort to lift their game with dealing with hazardous waste.  There are multiple layers of compliance issues related to hazardous waste handling, and, as with most regulations, a little education (TRAINING!!) goes a long way in understanding the game plan!  The intention of this blog is to provide a brief discussion of the key regulations and their associated training requirements.

The Rules


The U.S. Environmental Protection Agency (EPA) has very strict guidelines regarding the generation, transportation, treatment, storage  and disposal of Hazardous Waste, which “ General Industry” businesses (schools, colleges; hospitals; trucking/freight companies; manufacturer; laboratories; …well, just about everyone) needs to know!
OSHA uses the term "general industry" to refer to all industries not included in agriculture, construction or maritime. General industries are regulated by OSHA's general industry standards, directives, and standard interpretations.

Give me an R! Give me a C ! Give me an R! Give me an A! What’s that spell?!  HAZARDOUS WASTE!

The Resource Conservation and Recovery Act (RCRA) appeared on the environmental scene in 1976 after Congress decided that people shouldn’t be building homes on top of highly hazardous waste dumps or Farmer Joe shouldn’t have a side business of burying industrial waste on the family farm.   RCRA is a complex law with lots of parts and many industries are affected by its components.  In addition to being complex, the text of the Act with all of its parts and sections is hard to follow.  My primary technical focus tends to be on the Generators of Hazardous Waste (40 CFR Part 262) . RCRA Training requirements for generators can be found in 40 CFR 262.34(a)(4) which conveniently (NOT) refers you to look at 40 CFR 265.16 on Personnel Training.

But the EPA’s RCRA law is not the only player when it comes to the game of shipping hazardous waste off your site.  The other major player is the Department of Transportation (DOT), and its Hazardous Materials shipping training requirements are found in 49 CFR Part 172, Subpart H.   The International Air  Transport Association (IATA) has rules for the air transport of hazardous materials ( http://www.iata.org/) including training requirements.

To simplify, RCRA is all about Hazardous WASTE and the DOT and IATA rules kick in when you’re dealing with hazardous MATERIALS, and guess what hazardous waste is?  That’s right it’s hazardous materials in DOT and IATA eyes.  For those who generate or ship Hazardous Waste, compliance for with EPA RCRA and DOT /IATA rules starts with required and effective training.

The Required Training


So, if you generate hazardous waste and you need to get it off your site, here is a brief summary of the training employees who either generate or handle hazardous waste should have -- per both EPA and DOT/IATA.

All employees at sites that generate hazardous waste need to be trained in how to:

  • Properly identify what qualifies as regulated “Hazardous Waste” per federal (EPA) or your state requirements.

  • Know where to properly dispose of any hazardous waste you may generate (I will give you a hint:   It’s NOT down the sink drain!).

  • Know how to handle and dispose of highly hazardous waste (very toxic, reactive or explosive) to prevent injuries, and who to contact for questions or emergencies.


Employees who are designated as responsible for the management and control of this hazardous waste need additional training. And, depending on the size of the facility, it is prudent to provide this training to a backup employee or two. This additional training includes how to

  • Properly label containers

  • Implement accumulation area requirements and time-on-site limits

  • Inspect hazardous waste accumulation areas for leaking or damaged containers or other problems

  • Complete Hazardous Waste shipping manifests

  • Ensure proper shipping methods and a qualified transporter are used

  • Develop site-specific procedures

  • Know and implement emergency procedures and site contingency plans


Refresher Training


A common point of confusion is when refresher training is needed for employees.  The DOT and EPA have two separate requirements:

  • The EPA requires annual refresher training for their regulations.

  • The DOT requires refresher training every 3 years for their regulations.


And, companies must ensure training for new employees or those newly assigned to the role within 6 months of their new post to be in compliance with both RCRA and DOT regulations .

The Bottom Line

We can all help to ensure clean air, clean soil and clean water in our neighborhoods by understanding and following federal and state hazardous waste/hazardous materials regulations. When accidents happen (and they do), labeling, manifests, emergency plans – everything that DOT/IATA and RCRA training develops for your company – are vital in the cleanup of the environment and protection of employee and public health and safety.

For more information or questions regarding how to handle hazardous waste or where to obtain training, please comment below or contact Emilcott.  As part of  The Emilcott Training Institute, we offer private hazardous communication, hazardous materials and hazardous waste training specific to company or site needs. We also offer public classes for both DOT/IATA and RCRA:
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Topics: OSHA, Emilcott, General EHS, EPA, Emergency Response, H&S Training, DOT, Hazardous Waste Management, Hazardous Materials, Compliance, Lab Safety & Electrical, regulation, General Industry, emergency response training, Occupational Training, IATA, Resource Conservation and Recovery Act, Lab Safety, hazwaste, transportation, hazmat, generation, RCRA

Does DOT/IATA Training for Transportation of Hazardous Materials Prevent Incidents?

Posted by Shivi Kakar

Feb 14, 2011 3:11:26 AM

Capt. John DeFillippo, CHMP, EMT-B

“Every day there are more than 800,000 shipments of hazardous materials (hazmat) in trucks-usually flammable liquids, such as gasoline, or flammable gas. About 200 hazmat trucks a year are involved in fatal crashes and 5,000 in nonfatal crashes. Although these numbers are small relative to the totals of almost 5,000 trucks involved in fatal crashes and 400,000 involved in nonfatal crashes annually, the potential for human injury and property damage in hazmat crashes is much greater.”

Ralph Craft, Ph.D.
Analysis Division, Office of Information Management, US Department of Transportation

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Topics: General Industry H&S, Emilcott, General EHS, H&S Training, DOT, Hazardous Waste Management, HazCom, Hazardous Materials, Compliance, Occupational Safety, regulation, Hazard Communication Standard, Public Safety, Lab Safety

2010 Holiday Planning Includes 2011 EPA Submission Deadlines

Posted by Shivi Kakar

Dec 19, 2010 9:17:09 PM

Dian Cucchisi, PhD, CHMM

Another calendar year is drawing to a close; where does the time go?  As I plan my own holiday celebrations and commitments, environmental professionals like me have another type of planning to keep in mind.  With the start of each new year, we face regulatory submission deadlines reporting data from the past year including Submission of the EPA Community Right to Know (CRTK) Survey -- a Federal act with each state managing their own program due March 1 st and EPA Toxics Release Inventory (TRI) due July 1 st.

Just like Christmas shopping, the compilation and reporting process is less stressful and yields better results if I begin early and develop a strategy with deadlines in mind.  As such, here is my personal January 1 st kick-off list that should make the time-consuming process of CRTK and TRI reporting easier to handle.   

1)      Start requesting and gathering all the information needed for these submittals.

  1. 2010 purchasing records of the chemicals you are reporting

  2. 2010 production logs where these chemicals are used

  3. 2010 waste information

  4. 2010 recycling information for any reported chemicals that were recycled

  5. 2010 air emission inventory


2)       Develop and write down a comprehensive set of due dates so that you have time to review information as it comes in. If the requested data is late, have a plan to follow up or find another source because the deadline is not going to change!

3)      Review the rules early to avoid unpleasant surprises.  For example, The Environmental Protection Agency (EPA) finalized a rule effective November 10, 2010 which added 16 chemicals to the list of TRI reportable chemicals.  To ensure that you are reporting what you need to report, check the TRI database on the EPA website:   http://www.epa.gov/tri/trichemicals/index.htm.

4)      Allow time for anomalies and additional fact-finding. As Charles Peruffo described in a recent EHSWire blog about filing the NJ PPA, reported amounts from different sources may not match. If you find that is the case, it’s your job to figure out why and that always adds more time to the already challenging process.

Emilcott’s clients depend on our environmental knowledge and organizational capabilities to gather the required information on time and give them fair warning if there is trouble ahead.  My best advice for successful reporting-don’t wait until the last minute.  Much like shopping for Christmas on Dec 24th, waiting until February to gather the information for the CRTK or starting in June for the TRI will be stressful and could result in costly errors. So, what am I doing today?  Like Santa, I’m checking my own list twice! 

Have you been meeting the CRTK and TRI deadline? If yes, can you offer additional advice or do you have particular steps that you take to get the submission process rolling?
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Topics: General EHS, EPA, Hazardous Waste Management, HazCom, Hazardous Materials, reporting, Toxics Release Inventory, emissions, Community Right to Know, haz waste, TRI, CRTK, chemical

The Future of Air Monitoring: Real-time Particle Size Measurement

Posted by Shivi Kakar

Dec 12, 2010 9:31:15 PM

Bruce Groves

Why do we care about particles floating around in our air? Small, inhalable particles are themselves pollutants that have shown to cause illness and chronic diseases such as asthma and certain types of lung cancer . Particles are also excellent indicators (or surrogates) for measuring other pollutants such as vapors and gases. By measuring the aerodynamic size of particles in our air, it is possible to identify and sometimes “fingerprint” them so that we can reduce or stop local sources of pollution immediately. The goal AND end result are to develop as clean a living and working area as possible.

What are we doing today?


Today, air monitoring is a piecemeal approach that is government-mandated but generally project related. When the project is over, the problem is essentially considered to be gone. Of course, in areas of high population density or industrial activity, continuous, real-time air monitoring of general conditions does not exist. Other than pollen counts, very little information about these pockets of high pollution and high particulates is available to the public or government agencies. And, the data that is available is generally much later and does not present an accurate picture of today’s problem.

What is the future in environmental air monitoring?


As technology has improved, so have particle detectors and the ease of data transmission and analysis. By 2013, small particle size detectors, such as those found in the Greenlight Environmental Monitoring System, will be consistently deployed in high population areas in such cities such as NYC, Tokyo, London and Los Angeles. These particle size detectors will be coupled with wind-speed and direction detectors and web cameras to pinpoint the exact sources of particle emissions (e.g., construction or industrial equipment, idling vehicles or high traffic transportation corridors) that are creating a measurable increase in local air pollution.

This web of detector stations will form an active or “live” map of a city that continuously measures and reports the concentration of various particle sizes. The “map” will be automatically programmed to provide warning levels and alarms to reveal when and where total particle concentrations exceed warning and safe threshold levels. By locating (in real time) the place, the direction of the pollution source and supporting video evidence, private companies and government agencies can take measures to stop or reduce the indicated pollution sources. Constant real-time monitoring, assessment and action will provide continuous improvement in local air quality that will reduce the onset of disease associated with inhaling dirty air. Warning systems set up through websites will enable agencies and individuals to check on their local air pollution conditions using their computer or smart phone.

What is the first step?


At Emilcott, we have been working with particulate monitoring on job sites for over 25 years. As an extension of our field experience, we’re working on a solution that meets the needs of our clients (private companies and government agencies) -- the Greenlight Environmental Monitoring System. With multiple project implementations under its belt, the Greenlight System’s particle size measurement, assessment and reporting capabilities are demonstrating how real-time monitoring is helping projects get cleaner each day – reducing the liabilities of our clients while giving them the information to keep the public and workers safe.

As the Greenlight System’s next phase of engineering development is outlined, our goal is to have a universal system that will provide comprehensive sampling in potentially high pollution areas so that neighborhood air quality can be improved and the incidence of lung disease is reduced. It will be a future watchdog for providing cleaner air locally where no such means of protecting local air quality exists today.

What do you think the future of environmental air monitoring holds? What are the benefits or challenges that you associate with monitoring and mapping pollutants in a broad geographic area?
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Topics: Emilcott, Construction H&S, EPA, Emergency Response, Homeland Security, Hazardous Waste Management, health and safety, Hazardous Materials, worker safety, Occupational Health, indoor air quality, Air Sampling, Greenlight System, Exposure, environmental air monitoring, Respiratory, Public Safety, perimeter air monitoring

New Large Vehicle Greenhouse Gas Emission Standards from EPA

Posted by Shivi Kakar

Nov 28, 2010 11:22:41 PM

Megan Grennille

Your next visit to a truck stop may be more pleasant in a few years.  New standards were announced on October 25th from the DOT (Department of Transportation) and EPA (Environmental Protection Agency) to reduce greenhouse gas emissions in heavy-duty trucks and buses.  The standards, which are set to be phased in on new vehicles in 2014, will include requirements to improve fuel efficiency which benefits businesses, the shipping industry, and cities and towns.

The large vehicles being targeted by the proposed standards are divided into three categories: combination tractors, heavy duty pickups and vans, and vocational vehicles.  Combination tractors will have a 20% decrease in CO 2 output as well as fuel consumption.  Heavy-duty pickup trucks and vans will have separate gas and diesel standards; by 2018 CO 2 emissions and fuel consumption will decrease by 10% in gas vehicles and 15% for diesel.  Vocational vehicles, such as buses and utility trucks, could see a 10% reduction in fuel consumption and CO 2 emissions by 2018.  

The new regulations bring environmental and economic benefits.  People who live near bus depots, cities, and highways should be happy.  And, on those hot smoggy days near the end of this decade, the air will be a little cleaner.

What do you think of the regulations? Will they impact your business?
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Topics: General EHS, EPA, DOT, Hazardous Materials, worker safety, Occupational Health, indoor air quality, Air Sampling, Exposure, chemicals, environmental air monitoring, Working Green, greenhouse gas emissions

Why Proper Respirator Protection Lets You Breathe Longer (and Breathe Easy)

Posted by Shivi Kakar

Nov 1, 2010 12:56:53 AM

Capt. John DeFillippo, CHMP, EMT-B

The health effects from airborne hazards are a frequent topic in many health and safety courses, especially in hazardous substance and hazardous waste training.  This is because so many of these exposures may not show up as health problems for decades! Consider asbestos. While it’s not harmful to the touch, inhalation can be fatal, but it can take 25-30 years before asbestosis or mesothelioma can develop. Both are chronic and often deadly diseases of the lungs.

The lungs are amazing. It surprises most people to learn that the lungs have the largest surface area of any body organ -- about 80 times more area than the skin, or about the size of a tennis court!  As we breathe, our lungs are in constant contact with the outside world and that is a lot of contact area. They need to be protected.

Over three million American workers are required to wear respirators to protect themselves from hazardous airborne contaminants.  Not surprisingly, OSHA has some pretty strict rules when it comes to protecting our lungs . Despite this , it is estimated that more than half of the respirators worn are not worn in accordance with OSHA Standard 29 CFR 1910.134

Did you know that…

  • If workers are wearing respirators, a written program is required?

  • A medical evaluation is required for anyone who wears a respirator?

  • A fit test of each respirator worn must be conducted initially AND annually?

  • The workplace must be evaluated to determine the hazard so that the proper respirator (there are many) can be selected?

  • These rules, and others, apply to what many people refer to as “dust masks”?


Proper respirator usage training is also required. Why? Because wearing the wrong type, wrong size, or an improperly fitted respirator can be more dangerous than not wearing one at all. For example:

  1. Wearing a filtering respirator in an O2-deficient atmosphere, or the wrong cartridge, can mislead you to believe that you are protected…when you are not!

  2. A mask with even the slightest poor fit allows contaminates in and may actually increase exposure levels.

  3. Not everyone can wear a respirator. Because a respirator restricts your breathing, people with certain medical conditions can be seriously harmed by wearing them. This is why being medically cleared prior to use is so important, and required.


Not complying with the rules designed for occupational safety can be costly… and not just in fines and penalties. Too many workers have destroyed their health by failing to protect their delicate, vital lungs. And, it’s not just at work. Working around the home and yard can also present respiratory dangers, too. If you are not sure that you need more than a “dust mask” ask someone who can help.

Have you been properly trained to use your respirator and fit-tested to make sure it is actually stopping hazards from reaching your lungs?Are you confident that you are using your respirator properly and that the respirator that you have selected is the best for the contaminants you are exposed to?  How about the person next to you - are they in compliance?  Hopefully you and your workmates can answerYES! to these questions. If you have any questions about respiratory protection, please ask me!
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Topics: OSHA, General Industry H&S, General EHS, Construction H&S, Emergency Response, Homeland Security, H&S Training, Hazardous Waste Management, Hazardous Materials, Compliance, worker safety, Occupational Health, Occupational Safety, indoor air quality, Lab Safety & Electrical, Personal Protective Equipment, emergency response training, Fire Safety, environmental air monitoring, Respiratory, Occupational Training

EPA Proposed Changes to the TSCA Inventory Update Rule (IUR)

Posted by Shivi Kakar

Sep 13, 2010 12:00:15 AM


Paula Kaufmann, CIH

In a recent blog about the rapidly approaching Toxic Substance Control Act (TSCA) Form U submission in 2011, I mentioned that the EPA published a Proposed Rule detailing TSCA Inventory Update Reporting Modifications. The EPA anticipates promulgating a final rule by the spring of 2011 as the next scheduled IUR submission period is currently scheduled to run from June 1, 2011 through September 30, 2011.

Some of these modifications are really a big deal and will require a lot additional effort for most submitters. We should be seeing some commentary in response to the proposed rule about the cost of compliance with the modifications along with the benefits of having this collection of information about chemical importation, manufacture and use in the US. Hopefully this will be a spirited discussion and we will keep you posted on the outcomes and what they mean to you.

Although we don’t know what the final rule will look…the following is a list of the proposed changes that may affect many of our clients and you:

  • Electronic reporting of the IUR data, using an Agency-provided, web-based reporting software

    • After the final rule’s effective date, paper submissions would no longer be accepted.



  • Form U submission every 4 years (instead of every 5 years)

  • All submissions would require processing and use information (Part III of Form U)

  • No minimum manufacture (or import) quantity for certain chemical substances

    • This an elimination of the 25,000 lb. threshold for the chemical substances that are subject to rules or orders in following TSCA sections:

      • Section 5(a)(2) Significant New Use Rules (SNURs)

      • Section 5(b)(4) Chemicals of concern to EPA

      • Section 6 Prohibitions for chemicals with unreasonable risks

      • Section 5(e) Requirements or restrictions on chemical production or use

      • Section 5(f) Chemical with an unreasonable risk





  • IUR exemption changes for the following chemical substances:

    • No exemption for those with an enforceable consent agreement (ECA) to conduct testing.

    • Full exemption water.

    • Removal of polymers that are already fully exempt from the partially exempt list of chemical substances.



  • Significant new reporting requirements Form U completion:

    • Name and address belonging to the parent company.

    • Current Chemical Abstracts (CA) Index Name, as used to list the chemical substance on the TSCA Inventory, as part of the chemical identity.

    • Production volume for each of the years since the last principal reporting year. For the 2011 report this would include 2006, 2007, 2008 AND 2009 in addition to 2010.

    • Production volume directly exported and not domestically processed or used.

    • Volume of manufactured chemical substance (such as a by product) that is recycled, remanufactured, reprocessed, reused, or reworked .

    • Company Business Information (CBI)

      • Submission of substantiation for CBI claims in Section III (processing and use information).





  • Proposed changes for AFTER 2011 Form U submissions

    • Require reporting if the production volume of a substance met or exceeded the 25,000 pound threshold in any calendar year since the last principal reporting year.




With this significant list of proposed changes, Emilcott is paying close attention to TSCA-related news so that we can advise and guide our clients to be in compliance. We have worked with multiple U.S. and International clients with U.S. facilities that have misunderstood or ignored TSCA regulations resulting in a big problem that could have been avoided. If your facility falls under the TSCA guidelines, are you paying close attention to modifications to the TSCA IUR program? What do you think of the company cost vs. informational and monitoring benefits? What are you doing to be a part of the debate or prepare for submission?
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Topics: Emilcott, General EHS, EPA, Hazardous Materials, Compliance, TSCA & R.E.A.C.H., TSCA, Toxic Substance Control Act, reporting, chemical manufacturer, regulation, chemicals, regulatory

TSCA Form U Submission Year is 2012 (no longer 2011)!!!

Posted by Shivi Kakar

Sep 8, 2010 12:07:44 AM

Paula Kaufmann, CIH

August 2011 Update:   Information from the EPA regarding TSCA requirements and submission has changed significantly since this post was originally written in August 2010. Please also read BREAKING NEWS: New EPA TSCA Inventory Update Requirements (IUR) for 2012   and additional posts following to ensure that you have the most up-to-date information.

-PKaufmann

Is your facility a manufacturer or importer of chemicals in amounts of 25,000 pounds or greater?  If so, your company may need to participate in the next round of the EPA’s Toxic Substance Control Act (TSCA) Inventory Update Rule (IUR) program and submit a Form U to the EPA.

Here’s how the EPA explains this rule:  “The IUR  requires manufacturers and importers of chemical substances included on the TSCA Chemical Substance Inventory to report site and manufacturing information for chemicals manufactured (including imported) in amounts of 25,000 pounds or greater at a single site.  Additional information on domestic processing and use must be reported for chemicals manufactured in amounts of 300,000 pounds or more at a single site. EPA uses the IUR data to support many health, safety, and environmental protection activities.”  For more information go to http://www.epa.gov/oppt/iur/

When Is the Next Reporting? THIS IS IMPORTANT!!!

The next submission period is currently planned for June 1 - September 30, 2011 when manufacturers and importers will report information on their 2010 production (and the EPA has proposed adding data for years 2006, 2007, 2008 and 2009) . See revised information post:   BREAKING NEWS: New EPA TSCA Inventory Update Requirements (IUR) for 2012

How is IUR Changing for 2011 Reporting?

  1. Inorganic chemicals are no longer partially exempt from the IUR rule. This was a one-time exemption for 2006 reporting only.

  2. On August 13, 2010 the EPA published its proposed IUR Modifications Rule, beginning a 60-day comment period. The proposal would require electronic reporting and expanded manufacturing, processing, and use information.  The EPA anticipates promulgating a final rule by the spring of 2011. As aspects of the proposed rule have yet to  be finalized, Emilcott will  provide a definitive, easy-to-read list here on EHSWire.


So…stay tuned to EHSwire.com or www.emilcott.com to stay informed about any IUR reporting developments and reporting obligations in 2011 for the calendar year 2010.   If you have any questions about the upcoming IUR reporting or TSCA compliance question, please comment below, contact us directly or read more at http://www.emilcott.com/services/svcenvcompliance.asp.  Emilcott provides comprehensive support for TSCA compliance, including assisting with inventory and chemical substance use information subject to the IUR program.

Some interesting Form U questions and facts -

Did you know that 1,541 companies submitted a Form U in 2006?

Some submitted multiple Forms because as each manufacturing site that originates a chemical substance is required to report. The 2006 IUR public data are available on the IUR web site (www.epa.gov/iur).

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Topics: EPA, Hazardous Waste Management, Hazardous Materials, Compliance, TSCA & R.E.A.C.H., TSCA, Toxic Substance Control Act, reporting, chemical manufacturer, regulation, chemicals, regul

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