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Now that EPA has scheduled the submission period and defined what has to be reported, and how it must be done, Emilcott’s EHS group is compiling a centralized, online resource to help our clients complete the reporting process accurately and on time including email summaries of the revised requirements and critical changes to the 2012 Form U submission, notification of EPA seminars and other TSCA-related activities and free, informational TSCA-related webinars. We have some news on this year’s TSCA IUR Form U submission: this year’s Form U submission period will not be June 1 to September 30. It will most likely be pushed back to later this year. 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. In the August 13, 2010 TSCA Inventory Update Reporting Modifications – Proposed Rule, the EPA anticipated the promulgation of the final rule by the Spring of 2011. Spring arrived 3 weeks ago, and the final IUR Reporting Modification rule has not been published. As such, the reporting modifications and specific reporting period have not been finalized. In addition, the Agency has not released a test version of the revised Form U electronic reporting software. It is possible that the Agency will change the proposed 2011 submission period (June 1 – September 30) to another 4–month period later in 2011. Emilcott has created a handy quick reference table of “EHS Regulatory Submissions and Postings for January thru April 2011″. Each submission has links to more detailed explanations and weblinks — a gentle reminder to get organized! Included are EPA TSCA New Chemicals, EPA Greenhouse Gas Reporting, OSHA Recording and Reporting, NJ Emission Statement Rule, Emergency Planning and Community Right-to-Know Act, and the NPDES Stormwater Program. It’s time for an update on the EPA’s proposed changes to the Inventory Update Reporting Rule! As of January 24, 2011, the EPA has been silent as to what changes will be included in the final rule. Paula Kaufmann makes an education guess to forecast when the final rule will be published so that anyone required to report, under TSCA rules, can collect their 2010 inventory data. Click on the title of the blog to read more. Are you in litigation regarding an environmental, health or safety issue? if so, there is a good chance that both plaintiff and defendant counsel will enlist the services of an expert or two. What is the role of an Expert Witness and how do you find the best EHS expert witness for you? For both counsel and client, spend the time to do research and find qualified EHS professionals who can help you win your case. Is your facility a manufacturer or importer of chemicals in amounts of 25,000 pounds or greater? If so, your company may need to participate in the next round of the EPA’s Toxic Substance Control Act (TSCA) Inventory Update Rule (IUR) program and submit a Form U to the EPA… August 2011 Update: Information from the EPA regarding TSCA requirements and submission has changed significantly since this post was originally written in August 2010. Please also read BREAKING NEWS: New EPA TSCA Inventory Update Requirements (IUR) for 2012 and additional posts following to ensure that you have the most up-to-date information. -PKaufmann Is your facility a manufacturer or importer of chemicals in amounts of 25,000 pounds or greater? The Bhopal Disaster has been in the news again with the eight former company executives getting convicted of negligence. A court in the Indian city of Bhopal returned the verdict on June 7, 2010, more than 25 years after the incident. What was the Bhopal Disaster? For those of us old enough to remember, the words “Bhopal, India” brings to mind the very tragic events of December 2, 1984. On that day a Get an EHS Design Expert at the Table!Paula Kaufmann – CIH I recently read an article titled “Implementing Safety during Design: a Case Study” in the March 2009 edition of AIHA publication, The Synergist. The authors discuss how incorporating safety systems or measures in the design phase of a construction project can result in large cost savings for the overall project budget. Studies have shown that implementing safety during the planning phases of a |
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