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Your Regulatory Submission Reminders for 2013

Posted by Shivi Kakar

Jan 30, 2013 10:55:00 AM


The following are important regulatory submission dates for 2013. These apply to regulations such as the EPA TSCA New Chemicals, OSHA Injury and Illness Recordkeepingand Reporting, the NJ Emission Statement Rule and many others. 




EPA TSCA New Chemicals

Companies who imported or manufactured a new polymer in 2012 that met the TSCA Exemption Criteria must submit a TSCA Polymer Exemption Report of manufacture or import by (postmarked) January 31, 2013.

The notice must include:

Manufacturer's (Importer’s) information: 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 2012 must be identified in the notice. 

Learn more about the EPA TSCA New Chemicals
Learn more about TSCA Polymer Exemption Report 
OSHA Injury and Illness Recordkeeping and Reporting

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 2012. This summary must remain posted from February 1 to April 30, 2013, 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 2012 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 2012 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 the OSHA Form 300A  


NJ Emission Statement Rule - Request of Non-Applicability

If a facility reported through the Emission Statement Rule 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 by February 1.

In addition to specified supporting documentation, the request should also contain the name and location of the facility, the facility ID (assigned by NJDEP), the name and telephone number of the plant contact and the Responsible Official of the facility. The person signing the letter and making the request for non-applicability must be a Responsible Official of the facility. Facilities are allowed to base their decision upon the work of consultants, but the ultimate responsibility for compliance still rests with the Responsible Official of the facility. 

Learn more about the NJ Emission Statement Rule  


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

Sites that have chemicals listed on the Environmental Hazardous Substance (EHS) list in quantities that exceeded 500 pounds at any given time during 2012, 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 were present on site in quantities that exceeded 10,000 pounds. This is required by the U.S. Environmental Protection Agency (EPA). Sites are required to complete and submit the survey by March 1, 2013.

On July 3, 2012, EPA amended the Emergency and Hazardous Chemical Inventory Forms under Section 312 of the Emergency Planning and Community Right-to-Know Act (EPCRA) to add new data elements and revise some existing data elements. The amendments are intended to meet the purpose of EPCRA, which is " encourage and support state and local planning for emergencies caused by the release of hazardous chemicals and to provide citizens and governments with information concerning potential chemical hazards present in their communities."

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 EPCRA


EPA Resource Conservation and Recovery Act (RCRA)

Generators of hazardous waste are required to submit reports to their state environmental protection agency detailing the hazardous waste activities of the previous year. Some states have aligned with the EPA to require submittal of the report every even numbered year with information of the previous year. Some states (such as New York) require submittal of the report every year.

For information on the New York hazardous waste annual reports: Click Here

For information the New Jersey hazardous waste biennial reports: Click Here


National Pollutant Discharge Elimination System (NPDES) Stormwater Permit Program

Facilities with stormwater discharge permits are required to submit to the applicable state agency an annual report summarizing their comprehensive site inspection and corrective actions taken during 2012. 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 EPA Stormwater Regulatory Requirements, NJ Industrial Stormwater Permitting Program and NY Stormwater Programs 



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Topics: Emilcott, EPCRA Section 312, NPDES, EPA TSCA, OSHA Injury, NJ Emission Rule, EPA Resource Conservation and Recovery Act

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