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Environmental Health and Safety Blog | EHSWire

EHS Regulatory Updates and Due Dates (May - September 2011)

Posted by Shivi Kakar

Jan 1, 1980 1:00:00 AM

Paula Kaufmann, CIH

Here is the latest update of a handy table we create and email 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 this chart as a timely email reminder, "EHS Regulatory Submissions",  three times a year to keep our clients informed about upcoming deadlines. If you'd like to subscribe to that newsletter, just go to http://www.emilcott.com/subscribe.asp. If you need help with your Regulatory Submissions, don't wait! Contact Emilcott and ask for either an EHS or Hazardous Materials/Waste consultant.

Quick Reference Guide to Regulations and Submissions (May 2011)





















































RegulationSubmissionFrequencySUBMISSION DATE
NJ Emission Statement  RuleTSCA Polymer Exemption ReportAnnualJanuary 31
EPA TSCA IUR  Form U Certificates of RepresentationRegistrationJanuary 31
US DOT Hazardous Material RegistrationGHG 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

NJ Emission Statement Rule







The Emission Statement rule (N.J.A.C. 7:27-21) establishes requirements for the annual reporting of air contaminant emissions from stationary sources.  NJDEP requires emission data from all facilities that emit or have the Potential to Emit greater than or equal to the following thresholds:

  • 5 tons per year of Pb

  • 10 tons per year of VOC

  • 25 tons per year of NOx

  • 100 tons per year of any of the following -- CO, NH3, PM2.5, PM10, SO2, or TSP


A facility's Potential to Emit is determined for each air contaminant by totaling the following:

  • All allowable emissions from permitted sources

  • The emissions from all non-permitted sources operating at maximum capacity and assuming that the source operates for 8,760 hours per year; and

  • All maximum fugitive emissions.


Learn more about the NJ Emission Statement Program


Learn more about the NJ Emission Statement


EPA TSCA Inventory Update Reporting (IUR) Form U






The purpose of the IUR program is to collect quality screening-level, exposure-related information on chemical substances and to make that information available for use by EPA and, to the public. The IUR regulation requires manufacturers and importers of certain 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.



Learn more about TSCA IUR


Learn more about Form U



Read EHSWire TSCA-related blogs:


TSCA IUR Early Spring 2011 Update


TSCA IUR Update -- What are the changes?


EPA Proposed Changes to the TSCA IUR


TSCA Form U Submission Year is 2011!





US DOT Hazardous Material RegistrationAll shippers and transporters of specified categories of hazardous materials must submit an annual - registration statement and payment before July 1 or before engaging in any of the activities requiring registration.  This DOT certificate and registration number must be on record prior to shipment or transport of hazardous materials.

Registration can be submitted via the internet at the following url: https://hazmatonline.phmsa.dot.gov/services/haz_reg_1.aspx

Learn more about US DOT Hazardous Material Transportation Registration and Fee Assessment Program


Learn more about Hazardous Material Registration









EPA Toxic Chemical Release Inventory (TRI) / Form A or Form R





1990 Congress passed the Pollution Prevention Act which requires facilities to report additional data on waste management and source reduction activities to EPA under TRI. The goal of the Toxics Release Inventory Program is to provide communities with information about toxic chemical releases and waste management activities and to support informed decision making at all levels by industry, government, non-governmental organizations, and the public. The Toxics Release Inventory Program compiles the TRI data submitted by regulated facilities each year and makes the data available through the Data and Tools webpages.



Learn more about EPA Toxic Chemical Release Inventory Program


Learn more about Form A or B











EPA Toxic Chemical Release Inventory (TRI) / Form A or Form R

1990 Congress passed the Pollution Prevention Act which requires facilities to report additional data on waste management and source reduction activities to EPA under TRI. The goal of the Toxics Release Inventory Program is to provide communities with information about toxic chemical releases and waste management activities and to support informed decision making at all levels by industry, government, non-governmental organizations, and the public. The Toxics Release Inventory Program compiles the TRI data submitted by regulated facilities each year and makes the data available through the Data and Tools webpages.












EPA Toxic Chemical Release Inventory (TRI) / Form A or Form R

1990 Congress passed the Pollution Prevention Act which requires facilities to report additional data on waste management and source reduction activities to EPA under TRI. The goal of the Toxics Release Inventory Program is to provide communities with information about toxic chemical releases and waste management activities and to support informed decision making at all levels by industry, government, non-governmental organizations, and the public. The Toxics Release Inventory Program compiles the TRI data submitted by regulated facilities each year and makes the data available through the Data and Tools webpages.












EPA Toxic Chemical Release Inventory (TRI) / Form A or Form R

1990 Congress passed the Pollution Prevention Act which requires facilities to report additional data on waste management and source reduction activities to EPA under TRI. The goal of the Toxics Release Inventory Program is to provide communities with information about toxic chemical releases and waste management activities and to support informed decision making at all levels by industry, government, non-governmental organizations, and the public. The Toxics Release Inventory Program compiles the TRI data submitted by regulated facilities each year and makes the data available through the Data and Tools webpages.





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


Employers who have chemicals listed on the Environmental H











EPA Toxic Chemical Release Inventory (TRI) / Form A or Form R

1990 Congress passed the Pollution Prevention Act which requires facilities to report additional data on waste management and source reduction activities to EPA under TRI. The goal of the Toxics Release Inventory Program is to provide communities with information about toxic chemical releases and waste management activities and to support informed decision making at all levels by industry, government, non-governmental organizations, and the public. The Toxics Release Inventory Program compiles the TRI data submitted by regulated facilities each year and makes the data available through the Data and Tools webpages.





azardous 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













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