On March 1, each year facilities that use hazardous chemicals in specific quantities must file an EPCRA Tier II report identifying the chemicals with the State Emergency Response Commission, the Local Emergency Planning Committee, and the local fire department.
Easy to avoid mistakes and omissions in Tier II filings may lead to civil penalties of as much as $54.8K per day. Most cited violations involve just a few common chemicals such as ammonia, sulfuric acid inside equipment, and an EHS that is a component of mixtures. These are often overlooked or thought to be exempt from reporting because the threshold for reporting may be low.
Rather than risk non-compliance, ask the professionals at SCS Engineers about common chemical thresholds, voluntary self-disclosure, and EPA’s audit policies.
Read our most recent EPCRA Technical Bulletin, or contact us at .
SCS periodically prepares technical bulletins to highlight items of interest to our clients and friends. These are published on our website. This SCS Technical Bulletin addresses the Emergency Planning and Community Right-to-Know Act (EPCRA). The purpose of specific sections are consolidated and explained by SCS professionals; specifically:
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Author: Ann O’Brien
Alert: Toxic Release Inventory Form A and Form R Reports were due July 1, 2016
The Toxics Release Inventory (TRI) was created by EPA in response to several events that raised public concern about local preparedness for chemical emergencies and the availability of information on hazardous substances.
Printing is one of the industry sectors required to annually report releases of certain chemicals. A printing facility with 10 or more full-time equivalent employees is required to report if the facility exceeds established chemical thresholds. Note that TRI reporting is not based on the amount of emissions to atmosphere or how much waste is generated. Instead, a company that manufactures or processes more than 25,000 pounds or otherwise uses more than 10,000 pounds of a TRI-listed chemical were required to report releases of these chemicals by July 1, 2016.
There are currently over 650 chemicals covered by the TRI program including chemicals commonly used by printers, such as toluene, xylene, ethylbenzene, 1,2,4-trimethylbenzene, glycol ethers, solvents, and metals. Of particular interest to lithographic printers is the wide use of glycol ethers in fountain solutions and more recently in cleaning solutions, to take the place of solvents with high vapor pressures. It is important to mention that “glycol ethers” is a chemical category and within this category there are hundreds of individual chemicals that are reportable. Safety Data Sheets (SDS) do not indicate the presence of “glycol ethers” as a constituent of a raw material so a printer must look up each listed constituent and compare it to the list of TRI chemicals to determine whether is it reportable.
Ann O’Brien is a Project Manager with SCS Engineers. During her 32-year career in the printing industry she was responsible for environmental compliance programs, including, but not limited to, air and water quality permitting, environmental recordkeeping, reporting and monitoring programs, hazardous waste management, environmental compliance audits, and environmental site assessments and due diligence associated with real estate transactions and corporate acquisitions.
Cheryl Moran is a Project Manager with SCS Engineers with more than 20 years of experience in the printing industry. She is a Certified Hazardous Materials Manager (CHMM) and has worked with air, water, and waste issues including permitting, environmental recordkeeping, reporting and monitoring programs, hazardous waste management, environmental compliance audits, and sustainability programs.