It might feel like the July 1 deadline is far away, but it is time to start preparing to report your releases of toxic materials. The U.S. Environmental Protection Agency (USEPA) indicates that printing and related industries are subject to this report. It is an important part of your environmental compliance strategy if you have a facility with at least 10 full-time equivalent employees in a covered NAICS code that exceeded a reporting threshold in the previous calendar year. Reporting releases of toxic materials on an annual basis is one aspect of the Emergency Planning and Community Right-to-Know Act (EPCRA).
Consolidated List of Chemicals Subject to the Emergency Planning and Community Right To Know Act (EPCRA), Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA) and Section 112(r) of the Clean Air Act
Ann O’Brien of SCS Engineers has pulled together a list of questions that printers should be asking themselves before the environmental reporting season is upon us.
Use Ann’s questions as a guide to find out how ready your company is, and decrease your risk of non-compliance by being more organized.
If you don’t know the answers, ask Ann. She’s one of our air and water permitting, monitoring, and reporting experts at SCS. Ann specializes in printing industry compliance.
SCS Engineers provides a free guide to the most common environmental reports due at the federal and state levels. Each guide includes an overview of the reporting due along with the date each state requires submission.
When SCS says free, we mean it. No need to submit your company name, no endless email trail will follow; these are free guides to download and share with others from the compliance experts – SCS Engineers.
Click to download or share each state guide:
If your state is not listed, contact the nearest SCS office to speak with a compliance professional in your area and in your business sector; SCS is nationwide.
If you have questions or need help sorting out details such as which reports apply to your business or step-by-step support on how to prepare your reports in the states listed above, contact our regional professionals.
Learn more about Ann
Ann O’Brien 1-773-775-6362
Learn more about Cheryl
Cheryl Moran 1-608-216-7325
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.