Environmental Services: Compliance and Permitting

By Jim Euler posted 06-15-2018 10:49 AM

  

Toxic release inventories, or TRIs (Form R), are due on July 1st from facilities that release, manufacture, or use EPCRA Section 313 chemicals above EPA thresholds (over 25,000 lbs). Facilities must report, using Form R, quantities of 313 chemicals used during the calendar year to the EPA, including chemicals in waste onsite and offsite, as well as accidental releases. Regardless of whether TRI reporting is applicable, the methodology and supporting calculations need to be established to prove reporting is required, or NOT required.

Though they are experts in what they do, companies may not understand all the rules or have the reporting methodologies in place to create a complete and correct TRI. A solid reporting process allows a company to track all chemical activities, search the past calendar year to see what was used, made and released, and calculate the correct amounts of 313 chemicals. For example, a product manufacturer uses paints, hardeners and chemicals that contain toluene. To complete the Form R, this company must add up all the paint and the percentage values of toluene used throughout the entire year to see if they are above limits. If they use over 25,000 lbs. of toluene, they must report it in their TRI; if under, they do not have to report it, but they still need to be able to prove they used an under-limit amount of toluene. This process must take place for each 313 chemical the company has—and there are steep fines for those who file an incorrect, incomplete, or late form. Unfortunately, this process is easy to get wrong as there are many complexities involved including identifying and reporting coincidentally manufactured chemicals.

DECA Environmental provides TRI services to make it easier for companies to stay compliant and avoid potential fines.

Online SDS System: This paperless system allows companies to manage all of their SDSs in one central database, which they can share with each of their locations. Each SDS has 35 fields of information indexed, including the CAS# for each constituent within the chemical. If using the online SDS system alone, a simple Form R report can be generated to identify which chemicals contain 313 ingredients, and the percentages of each.

Environmental Reporting System: This service links directly to our Online SDS System and allows companies to input purchase records of each chemical used at their plants. Once the data input is completed, ACTUAL pounds of 313 reportable chemicals are calculated and a determination can be made from one report. The system provides all of the information an EPA inspector would expect to see during an audit.

DECA Environmental can still help companies that do not have these online services. We can work with a company’s own chemical usage management system to complete a TRI. Our established methodology is a proven system of due diligence and accurate record keeping that has reduced our clients’ fines even as drastically as from $40k to $0. Having a knowledgeable partner in environmental compliance means reporting can be done more efficiently and cost-effectively than doing it yourself.

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