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Environmental Health and Safety Blog | EHSWire

Regulatory Submissions & Postings Reminder (January thru April 2011)

Posted by Shivi Kakar

Feb 6, 2011 9:20:28 PM

Paula Kaufmann, CIH

Here is a handy table we recently created for our clients -- a gentle reminder to get organized! Even if you miss a deadline, it's better to start playing catchup as soon as you find out that you are not in compliance.

Want to stay informed? Emilcott publishes a timely email reminder, "EHS Regulatory Submissions", 3x/year to keep our clients informed about upcoming deadlines. If you'd like to subscribe to that newsletter, just go to If you need help with your Regulatory Submissions, contact Emilcott and ask for either an EHS or Hazardous Materials/Waste consultant.

Quick Reference Guide to Regulations and Submissions (Jan-Apr 2011)

RegulationSubmissionFrequencySUBMISSION DATE
EPA TSCA New ChemicalsTSCA Polymer Exemption ReportAnnualJanuary 31
EPA Greenhouse Gas ReportingCertificates of RepresentationRegistrationJanuary 31
EPA Greenhouse Gas ReportingGHG ReportsAnnualMarch 31
OSHA Recordkeeping & Reporting Occupational Injuries & IllnessesOSHA Injury and Illness Log Summary – Form 300AAnnualPost Feb 1 thru April 30
NJ Emissions Statement RuleEmission StatementNon-applicability ReportAs WarrantedFeb 1
Emergency Planning and Community Right-to-Know Act (EPCRA) Section 312Community Right-to-Know (CRTK) Survey and Tier I or Tier II Inventory FormAnnualMarch 1
NPDES Stormwater ProgramAnnual CertificationAnnualVaries by State

EPA TSCA New Chemicals

Anyone who imports or manufactures a new polymer in 2010 that met the TSCA Exemption Criteria must submit a TSCA Polymer Exemption Report of manufacture or import by (postmarked) January 31 of the year subsequent to initial manufacture. The notice must include:

  • Manufacturer's name. This includes the name and address of the manufacturer and the name and telephone number of a technical contact.

  • Number of polymers manufactured or imported. The number of polymers manufactured under the terms of the exemption for the first time in 2010 must be identified in the notice.

Learn more about the EPA TSCA New Chemicals

Learn more TSCA Polymer Exemption Report

EPA Greenhouse Gas Reporting

Suppliers of fossil fuels or industrial GHGs, manufacturers of vehicles and engines, and facilities that emit 25,000 metric tons or more per year of GHG emissions are required to submit annual reports to EPA. Reporting is at the facility level, except for certain suppliers of fossil fuels and industrial greenhouse gases. On October 30, 2009, the U.S. Environmental Protection Agency (EPA) published a rule for the mandatory reporting of greenhouse gases (GHG) from large US GHG emissions sources. Implementation of 40 CFR Part 98 is referred to as the Greenhouse Gas Reporting Program (GHGRP). These reports must be electronically submitted to the EPA by March 31.

Learn more about EPA Greenhouse Gas Reporting

OSHA Recording and Reporting Occupational Injuries and Illnesses

OSHA requires employers to post a summary (OSHA Form 300A - not the OSHA 300 Log) of the total number of job-related injuries and illnesses that occurred in 2010. This summary must remain posted from February 1 to April 30, 2011, and a company executive must certify the annual summary indicating that the totals are correct and sign the form.

The summary must list the total numbers of job-related injuries and illnesses that occurred in 2010 and were logged on the OSHA 300 form. Employment information about the annual average number of employees and total hours worked during the calendar year is also required to assist in calculating incidence rates. Companies with no recordable injuries or illnesses in 2010 must post the form with zeros on the total line.

The summary form is to be displayed in a common area wherever notices to employees are usually posted. Employers must make a copy of the summary available to employees who move from worksite to worksite, such as construction workers, and employees who do not report to any fixed establishment on a regular basis.

Learn more about OSHA Form 300A

NJ Emission Statement Rule

If a facility reported through the Emission Statement rule (N.J.A.C. 7:27-21) in a prior year or was sent a reporting package for this rule by the Department and now believes it is not subject to Emission Statement reporting because the "Potential to Emit" from the facility is below all reporting thresholds for all air contaminants, the Responsible Official of the facility is required to submit a Notice of Non-Applicability to the NJ DEP by Feburary 1, and supporting documentation to the Department stating the specific reason for non-applicability.

Learn more about the NJ Emission Statement Rule

Emergency Planning and Community Right-to-Know Act (EPCRA) Section 312

Employers who have chemicals listed on the Environmental Hazardous Substance (EHS) list in quantities that exceed 500 pounds at any given time during 2010, are required to complete and submit an annual Community Right to Know Survey. In addition, substances on the federal list of extremely hazardous substances must be reported if they are present at the designated threshold (usually less than 500 pounds), as well as any chemical requiring a Material Safety Data Sheet that is present on site in quantities that exceed 10,000 pounds. This is required by the U.S. Environmental Protection Agency (EPA). Employers are required to complete and submit the survey by March 1, 2011.

The survey must be submitted to the state environmental protection agency (such as the New Jersey Department of Environmental Protection), and copies sent to the Local Emergency Planning Commission, local police and fire departments, and the local hospital.

Learn more about EPCRA

Additional CRTK Information on EHSWire

NPDES Stormwater Program

Stormwater discharge permittees are required to submit to the applicable state agency an annual report summarizing their comprehensive site inspection and corrective actions taken during 2010. Stormwater Pollution Prevention Requirements vary by state for construction and industrial activities.

New Jersey: The SPPP certification report must be submitted to the NJ DEP Bureau of Nonpoint Pollution Control as indicated in the site-specific NPDES permit.

New York: The annual certification report must be submitted by March 31 to the NYSDEC, Bureau of Water Permits.

Learn more about the NPDES Stormwater Program for construction and industrial activities

Topics: OSHA, health and safety, General Industry H&S, OSHA Compliance, General EHS, Construction H&S, EPA, Hazardous Waste Management, Compliance, worker safety, Occupational Health, Occupational Safety, TSCA & R.E.A.C.H., TSCA, reporting, Form 300, Greenhouse Gas Reporting

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