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)

-       Proteins (albumin, casein, gelatin, gluten, hemoglobin)

-       Enzymes

-       Polysaccharides (starch, cellulose, or gum)

-       Rubbers

-       Lignins

What polymeric substance are NOT exempt from reporting?

Those substances that result from hydrolysis, depolymerization, or chemical modification of polymers, regardless of the extent of these processes, if the final products are no longer polymeric (e.g., a mixture of amino acids that is the result of hydrolysis of a polypeptide), the chemical substances are not considered to be polymers and must be reported if not otherwise excluded.

If you need guidance for the EPA TSCA 2012 CDR Submission, Emilcott offers these helpful options

1. Contact Emilcott  directly with your questions about TSCA or other regulatory issues.
2. Subscribe to our free TSCA newsletter which delivers TSCA-related information just like this right to your mailbox.
3. Look for additional information at the Emilcott TSCA Center Page

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!

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 http://www.emilcott.com/subscribe.asp. 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)

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:

• 5 tons per year of Pb
• 10 tons per year of VOC
• 25 tons per year of NOx
• 100 tons per year of any of the following — CO, NH3, PM2.5, PM10, SO2, or TSP

A facility’s Potential to Emit is determined for each air contaminant by totaling the following:

• All allowable emissions from permitted sources
• The emissions from all non-permitted sources operating at maximum capacity and assuming that the source operates for 8,760 hours per year; and
• All maximum fugitive emissions.

Learn more about the NJ Emission Statement Program
Learn more about the NJ Emission Statement

EPA TSCA Inventory Update Reporting (IUR) Form

The purpose of the IUR program is to collect quality screening-level, exposure-related information on chemical substances and to make that information available for use by EPA and, to the public. The IUR regulation requires manufacturers and importers of certain chemical substances included on the TSCA Chemical Substance Inventory to report site and manufacturing information for chemicals manufactured (including imported) in amounts of 25,000 pounds or greater at a single site. Additional information on domestic processing and use must be reported for chemicals manufactured in amounts of 300,000 pounds or more at a single site.

Learn more about TSCA IUR

Learn more about Form U

Read EHSWire TSCA-related blogs:

DELAYED! TSCA Form U 2011 Submission Period

TSCA IUR Early Spring 2011 Update

TSCA IUR Update — What are the changes?

EPA Proposed Changes to the TSCA IUR

TSCA Form U Submission Year is 2011!

US DOT PHMSA Hazardous Material Registration

All shippers and transporters of specified categories of hazardous materials must submit an annual – registration statement and payment before July 1 or before engaging in any of the activities requiring registration. This DOT certificate and registration number must be on record prior to shipment or transport of hazardous materials.

Learn more about US DOT Hazardous Material Transportation Registration and Fee Assessment Program

Learn more about Hazardous Material Registration

EPA Toxic Chemical Release Inventory (TRI) / Form A or Form R

1990 Congress passed the Pollution Prevention Act which requires facilities to report additional data on waste management and source reduction activities to EPA under TRI. The goal of the Toxics Release Inventory Program is to provide communities with information about toxic chemical releases and waste management activities and to support informed decision making at all levels by industry, government, non-governmental organizations, and the public. The Toxics Release Inventory Program compiles the TRI data submitted by regulated facilities each year and makes the data available through the Data and Tools webpages.

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)?

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.”