ehs wire



blog horizontal banner

Environmental Health and Safety Blog | EHSWire

Keep in Mind – Polymers are EXEMPT from CDR Reporting!

Posted by Shivi Kakar

Jan 16, 2012 1:36:44 AM

As you begin to gather the information for your TSCA 2012 CDR submission, keep in mind that almost all polymers are exempt from reporting.

What polymeric substances are exempt from reporting?

  • Chemical substances described with the word fragments “*polym*”, “*alkyd”, or “oxylated” in the Chemical Abstracts (CA) Index Name

  • Chemical substance which is identified in the TSCA Master Inventory File as-    Siloxane(s) and silicone(s)

-       Silsesquioxane(s)

Read More

Topics: Emilcott, TSCA, CDR, CDR Reporting, polymeric substance, polymers, Uncategorized

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!
Read More

Topics: Emilcott, OSHA, health and safety, CFATS, Hazardous Materials, worker safety, Occupational Health, Occupational Safety, TSCA, Toxic Substance Control Act, Uncategorized, Mold

Regulatory Submissions Reminders (May 2011 - September 2011)

Posted by Shivi Kakar

May 23, 2011 3:53:38 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 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 DEP Bureau of Air Quality Planning NJ Emission Statement Program Emission Statement - 2010 Emission Statement Guidance Document and other forms are availableAnnualMay 15
EPA TSCA Inventory Update Reporting (IUR) Form U - Electronic Reporting: CDX Registration for the 2011 IUR not available as of May 23Every 4 years
2011, 2015
Final Rule Still Not Published by EPA
US DOT PHMSA Hazardous Materials Transportation; Registration and Fee Assessment Program Hazardous Material Registration - 2011-2012 Registration year begins on July 1, 2011. PHSMA service will accept registrations in early May.AnnualJune 30
EPA Toxic Chemical Release Inventory (TRI) Program EPA Toxic Chemical Release Inventory (TRI) Report
Form A or Form R
AnnualJuly 1
NJ DEP Pollution Prevention and Right to Know Programs New Jersey Release and Pollution Prevention Report (RPPR) Form DEQ-114AnnualJuly 1
NJ DEP Pollution Prevention and Right to Know ProgramsNew Jersey Pollution Prevention Plan Summary (P2 Plan) Form DEP-113AnnualJuly 1
NJ DEP Regulated Medical Waste Generator Registration Program Medical Waste Generator RegistrationAnnualJuly 21

NJ DEP Bureau of Air Quality 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:

Read More

Topics: Uncategorized

OSHA Clarifies – Workers Must Understand Training

Posted by Shivi Kakar

May 17, 2010 5:56:44 AM

Paula Kaufmann - CIH
The Occupational Safety and Health Administration (OSHA) recently issued a few memorandums that indicate a strong emphasis on enforcement of existing standards. One very important action is OSHA directing its compliance officers (the enforcers!) to check and make sure that workers are being trained in a language or a vocabulary they can understand.  A very recent OSHA directive applies to training workers in agriculture, construction, general industry, and maritime work places.

Since understanding the health and physical hazards present in the workplace along with the appropriate controls for protection is fundamental to a safe work environment, it is obvious that one needs to be trained in a language that is understood. Health and safety programs cannot be effective if the folks that programs are intended to protect cannot understand them!

Effective training (good teaching) is the key to transferring information from the experts to the workers who use this information. As we all learned during our school years, we learn best from teachers who are prepared, knowledgeable, engaging AND teach us at the level (or language) we understand. I learn the most from courses that encourage student interaction and involvement. At Emilcott, our goal is that our students learn how to identify hazards and properly use the workplace controls available to protect them from exposure to these hazards. Emilcott offers health and safety training classes in English and Spanish and more for just that reason!!

Some thoughts to consider, in writing this directive, OSHA did not need any new regulations or standards; it has always existed in the regulations and standards ( as Diego Tolosa mentioned in a blog posting last year). Also, this is the first time such a clear directive has been written to the compliance officers (and OSHA-required training has been “on the books” for about 40 years)!!!

Cheers to OSHA for clarifying these requirements as many workers will benefit. Let’s get the news out to employers.

Have you experienced a situation where health and safety training was presented only in English and some of the students only had minimal English fluency? Perhaps these workers spoke Spanish, Polish, Chinese, or Portuguese (this is common in the New York City metropolitan area). How did the course subject matter get communicated to these students? If tested in their native language, could these students demonstrate that they learned “enough” from the English-only training? How do you accommodate a multi-lingual workplace (our melting pot)?
Read More

Topics: Uncategorized

The Dying Dead Sea

Posted by Shivi Kakar

Oct 27, 2009 10:43:32 AM

Genya Mallach - CSP
As I was riding on a bus towards one of the world’s oldest ecological treasures, a sad site appeared; the famous Ein Gedi Resourt that attracted tourists from all over the world (and once was a few meters away from the water) now sits nearly 700 meters away from the waters of the Dead Sea. It’s great to be in the biggest natural SPA in the world, whose mud contains over 21 different minerals and said to have healing properties.

People from all over the world flock to this region to experience the atmosphere of the lowest spot of the earth and to also float on the mineral rich water, because it’s too hard put your feet down to the bottom, even if you are only 3 feet deep. The sea lies approximately 1,300 feet below the sea level, is approximately 76 km long, up to 18 km wide and it is 400 meters deep at the deepest point. Over the last 20 years the level of the sea has dropped by approximately one meter per year.

The sad part is that this magnificent wonder is disappearing and there is very little that can be done. One major reason is that the waters of the Jordan river, which once flowed into the sea, now merely is a trickle by the time it gets down to the sea. Most of it is being diverted for agriculture and drinking water. Also, this mineral rich water is being evaporated because of the industrial plants that extract the minerals. The evaporative losses are way too greater than the make-up from the Jordan river.

There have been several proposals to pump the water from the Mediterranean Sea or from the Red Sea, however, the Israeli experts claim that chemical and biological reactions produced by mixing Dead Sea water with seawater could change the blue color of the Dead Sea and may create deadly gases.

According to Amos Bein of the Geological Survey of Israel, the sea will continue falling about three feet a year for the next 150 years or so, until the water becomes so supersaturated with salt that evaporation effectively stops.  At that point, according to Bein, the surface of the Dead Sea will be one-third smaller and about 434 feet lower than today.  So “it is possible that the Dead Sea will never dry up."
Read More

Topics: Uncategorized

Regulatory Submissions Reminder for May-Sept 2011

Posted by Shivi Kakar

Jan 1, 1980 1:00:00 AM

Paula Kaufmann, CIH

Read More

Topics: Uncategorized

DELAYED!! TSCA Form U Submission 2011 Period

Posted by Shivi Kakar

Jan 1, 1980 1:00:00 AM

DELAYED!! TSCA Form U Submission 2011 PeriodPaula Kaufmann, CIH

We have some news on this year’s TSCA IUR Form U submission.  Well, it really isn’t information about the requirements – but we do know that this year’s Form U submission period will not be June 1 to September 30.  It will most likely be later this year.  So we all can move that task to another segment of the calendar year!

On May 11, 2011, the EPA issued a Federal Register Notice amending the Toxic Substances Control Act (TSCA) Inventory Update Reporting (IUR) regulations by delaying  the June 1 to September 30 submission period for the 2011 Form U reports.  The notice indicated that this delay will not alter the timing of subsequent submission periods (e.g., the submission period from June 1, 2016 to September 30, 2016).  This is an interesting statement as one of the changes included in the proposed IUR Rule is a change of the reporting period cycle to every four (4) years from the current five (5) year cycle. 

The EPA is delaying the submission period because the proposed IUR modifications rule has not yet been finalized. EPA expects to have the final version of the changes to the IUR reporting requirements in the near future. The revised 2011 submission period will be announced with the publication of the final IUR modification rule. 

How does this delay that the EPA rule refers to as a “suspension” affect what needs to be done for the 2010 reporting period?  It seems that the EPA will mandate a new submission period but it is not clear when this will be during 2011.

  • We are assuming that the reporting period will remain as the 2010 calendar year. 

  • Our next assumption, or guess, is that the Form U submission period will shift to September 1 to December 31, but that will require that the final rule on the IUR modifications be published very soon.

As “food” for thought … As recently as March 4, 2011, representatives from the American Petroleum Institute (API) met with the EPA presenting concerns about several aspects of the proposed IUR modifications rule.  One topic the API presented was that when the last set of revisions of the IUR was finalized in 2003 with the next reporting period was extended by one year shifting from 2004 to 2005 with Form U submission in 2006.  During 2004 and 2005, the EPA held many workshops and issued clarification and guidance documents.

And for now, we wait for the Final Rule, and hope that the data we have all collected for the 2010 reporting period will be adequate.  Our recommendations for what to do while we wait are my January blog “TSCA IUR Update – What Are the Changes?” we are advising Emilcott clients to proceed with the collection of 2010 inventory data with a threshold of 25,000 lbs.  Here are a couple of items to keep on your radar:

  • Be sure your list of manufactured chemicals is complete.  Your list should be based on all chemical processes and imported materials received at the site and not just on the products.

  • When calculating individual substance volumes – include imported mixtures with those manufactured at the site aggregating all mixtures containing that substance. 

...And, Emilcott will continue to keep you posted!

What to do if you need help or have questions?

If you need assistance related to the TSCA New Chemicals regulatory requirements or the potential changes due to the Inventory Update Reporting Rule, Emilcott can guide you through the reporting.

We can also help you navigate the maze of reporting a potential Form U violation from prior filing years to the EPA (See 

As more information becomes available from the EPA regarding the IUR and as testing of the electronic tool begins, Emilcott will keep you up-to-date via EHSWire and our "Regulatory Updates" Newsletter

Please give me a call at 1-800-886-3645 if you have any questions.



Read More

Topics: Uncategorized

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

Posted by Shivi Kakar

Jan 1, 1980 1:00:00 AM

Paula Kaufmann, CIH
Read More

Topics: Uncategorized

Subscribe to!


Latest Posts

Posts by category