Compared with the air quality monitoring methods of even a few years ago, today’s air monitor system offers its users a quicker, more effective, and comprehensive way to assess potential environmental hazards.

2nd Ave Subway Construction Muck House – What emissions from here are impacting the Local Air Quality?

The recently published article, “MTA: 2nd Avenue Subway Construction Not a Danger to Your Health,” responds to a rise in complaints about possible environmental health hazards from the construction. In the article, MTA Capital Construction President Michael Horodniceanu suggested the public faced no danger from the construction based on results from a fall 2011 Parsons Brinkerhoff (PB) air monitoring study.

The PB study highlights important facts and issues about the project and makes useful points about air quality monitoring in general; however, PB used the same traditional dust and vapor monitors and methods that were used at the World Trade Center recovery site in 2001.

In the last decade and especially over the last few years, superior air monitoring technologies have been developed and used to help ensure that emission rates from major hazardous waste remediation operations in the New York metropolitan area are kept as low as possible. The use of innovative, more effective, and more cost-saving air monitoring equipment and methods would have provided data for the PB study that would better support MTA’s assertions.

Greenlight Map View of Integrated Air Monitoring Data

• Differentiate the sources of air contaminants so that those associated with the construction can be distinguished from those of other background sources

• Determine when emission levels from the construction/remediation activity begin rising

• Deliver immediate information to construction management so that they can make timely decisions to protect workers and the public

• Measure the efficacy of engineering controls and work practices in reducing emission rates, even when concentrations are below project or regulatory safe levels

Given the options, PB and the MTA would have found these and other meaningful enhancements in air monitoring equipment and techniques valuable to the 2nd Avenue Subway construction project.

I encourage you to learn more about state-of-the-art air monitoring equipment, including integrated systems that allow users to make evidence-based decisions to protect workers and the public.

Second Avenue Subway (SAS) Project – Air Quality Monitoring Study of Construction Activities between 69th and 87th Street on Second Avenue

You can view the rule at HERE

One of the changes is the inclusion of an “Unclassified Hazards” category; a definition is provided below.  The U.S. Chemical Safety Board recently released a statement supporting the Unclassified Hazard category to allow for inclusion of combustible dust hazards on safety data sheets and labeling.

“Unclassified hazard” means a chemical for which there is scientific evidence identified during the classification process that it may pose an adverse physical or health effect when present in a workplace under normal conditions of use or in a foreseeable emergency, but the evidence does not currently meet the specified criteria for physical or health hazard classification in this section. This does not include adverse physical and health effects for which there is a hazard class addressed in this section.

It should also be noted that EPA began to make amendments in November of last year to regulations for the “Protection in the Workplace” (40 CFR 721.63) and “Hazard Communication Program” (40 CFR 721.72) components of the Significant New Uses of Chemical Substances regulations at 40 CFR 721 to align them with the GHS changes in the OSHA Hazard Communications Standard.

Want to stay informed? Emilcott publishes a timely email reminder, “EHS Regulatory Submissions”, 3x/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, contact Emilcott and ask for either an EHS or Hazardous Materials/Waste consultant.

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!

Paula Kaufmann, CIH

What are the basic criteria needed to support a confidentially claim on the 2012 CDR Submission? Any business with a trade secret or confidential chemical formula is definitely wondering about this very issue as they consider just how to file their 2012 CDR Form U.

The EPA has increased the requirements (as in, made it more challenging) for companies who want to justify a claim of Confidential Business Information (CBI) in their CDR submission. A summary of the CDR CBI criteria for 2012, along with the long list of questions that must be addressed to support this claim are as follows (from 40 CFR 2.208):

• The business must show that disclosure of the information is likely to cause substantial harm to the business’s competitive position.
• The confidentiality claim must be valid at the date of submission.
• The business can demonstrate that it has and still does protect the confidentiality of the information.
• The information is not (and hasn’t been) obtainable by others without the business’s consent.
• No statute specifically requires disclosure of the information.

What information can be claimed as Confidential Business Information (CBI) on the 2012 CDR Submission?

• Site
  • Identity of the manufacturing or importing site linked with a reportable chemical substance.  Site name, address, city, county, state, zip code, and Dun & Bradstreet number are protected.
  • The company name must also be claimed as confidential to protect the link between the chemical identity and the company name.

• Chemical Substance
  • Specific identity of a chemical substance (including Accession Number) — only if EPA treats the identity of that chemical substance as confidential on the TSCA Inventory.

• Processing and Use Information
  • Data associated with the processing and use information — if you think this information would reveal trade secrets or confidential commercial or financial information.

What needs to be substantiated for the confidentiality claim to be accepted (honored) by the EPA?

All claims need to be substantiated at the time of submission. A blank response or a response that is designated as “not known or reasonably ascertainable” may not be claimed as confidential.  There are specific questions for each type of claim as shown below -

Site

1. Has site information been linked with a chemical identity in any other Federal, State or local reporting scheme? For example, is the chemical identity linked to a facility in a filing under the Emergency Planning and Community Right-to-Know ACT (EPCRA) section 311, namely through a Material Safety Data Sheets (MSDS)? If so, identify all such schemes.  Was the linkage claimed as confidential in any of these instances?
2. What harmful effect, if any, to your competitive position or to your customer’s competitive position do you think would result from disclosure of the processing and use data and the chemical substance? How could a competitor use such information? Would the effects of disclosure be substantial? What is the causal relationship between the disclosure and the harmful effects?

Chemical Identity – the substantiation must be provided for each chemical substance claimed to be CBI

1. What harmful effects to your competitive position, if any, or to your supplier’s competitive position, do you think would result from the identity of the chemical substance being disclosed in connection with reporting under the CDR? How could a competitor use such information? Would the effects of disclosure be substantial? What is the causal relationship between the disclosure and the harmful effects?
2. For how long should confidential treatment be given? Until a specific date, the occurrence of a specific event, or permanently? Why?
3. Has the chemical substance been patented? If so, have you granted licenses to others with respect to the patent as it applies to the chemical substance? If the chemical substance has been patented, and therefore disclosed through the patent, why should it be treated as confidential?
4. Has the identity of the chemical substance been kept confidential to the extent that your competitors do not know it is being manufactured or imported for a commercial purpose by anyone?
5. Is the fact that the chemical substance is being manufactured (including imported) for a commercial purpose available to the public, for example, in technical journals, libraries, or State, local, or Federal agency public files?
6. What measures have you taken to prevent undesired disclosure of the fact that the chemical substance is being manufactured (including imported) for a commercial purpose?
7. To what extent has the fact that this chemical substance is manufactured (including imported) for commercial purposes been revealed to others? What precautions have been taken regarding these disclosures? Have there been public disclosures or disclosures to competitors?
8. Does this particular chemical substance leave the site of manufacture (including import) in any form (e.g., as product, effluent, emission)? If so, what measures have been taken to guard against the discovery of its identity?
9. If the chemical substance leaves the site in a product that is available to the public or your competitors can the chemical substance be identified by analysis of the product?
10. For what purpose do you manufacture (including import) the chemical substance?
11. Has EPA, another Federal agency, or any Federal court made any pertinent confidentiality determinations regarding this chemical substance? If so, please attach copies of such determinations.

Processing and Use Information - the substantiation must be provided for each process and use claimed to be CBI for a specific chemical substance

1. Is the identified use of this chemical substance publicly known? Has your company ever provided use information on the chemical substance that was not claimed as confidential?
2. What harmful effect, if any, to your competitive position or to your customer’s competitive position do you think would result from disclosure of the processing and use data and the chemical substance? How could a competitor use such information? Would the effects of disclosure be substantial? What is the causal relationship between the disclosure and the harmful effects?
3. Obviously, manufacturers and other businesses who filed a CBI in 2006 must revisit their eligibility for their 2012 filing. And, to continue their eligibility, consideration for the extra time and effort to prepare the required substantiation documentation. To put it in a nutshell, with the number and depth of the EPA’s questions that are involved, you better be prepared prior to making a CBI claim!

Did you file a CBI claim last year? Are you going to file a CBI claim for the same chemicals this year? If so, are you allowing for extra time (and budget!) to gather the substantiation information together? If not, why not?

The EPA hosted a 3-hour webinar on November 16, 2011 that reviewed the reporting process for the 2012 Chemical Data Reporting (CDR) Rule with a focus on joint reporting, considerations related to the reporting of byproducts, and updated information about registering for electronic reporting and for using the electronic reporting tool/  The EPA has posted the presentation slides online and expects to have a recording of the webinar available for viewing by December 1.

Webinar Take Aways – Still Many Questions

• The Agency has prepared a detailed instruction manual for the 2012 CDR that presents the reporting requirements using a decision logic diagram.
• Registration for the EPA Central Data Exchange (CDX) for CDR submission is scheduled to be opened on December 1.  The sign-up link will be posted on the IUR/CDR Home Page. (Emilcott will also post it on our TSCA Resource Web Page.)
• e-CDR web, the CDR reporting tool, is scheduled to be available in January.
• The TSCA Substance Registry Services (SRS) will be updated in January.
• Additional resources will continue to be posted at www.epa.gov/cdr.
• A few of the new requirements highlighted during the presentation brought in many questions during the subsequent 2-hour webinar Q&A – specifically concerning Contract Manufacturing, Joint Submission, and byproducts reporting.

Some of the questions not answered during the webinar that we found of particular interest are:

• What are the reporting responsibilities for toll manufacturers where the volume of a chemical made for one customer is less than 25,000 lbs but they manufacture for several customers putting the cumulative volume above the threshold?
• What does one do since the XML Schema that is currently posted does not function properly, and is stated to be the final version?
• Does starting material that is recycled (and reused) need to be reported since the material was not manufactured at the site?
• If off-specification material is reprocessed, does the material gained from the reprocessing get reported as a byproduct or is it included in the overall production volume?
• How does one account for non-isolated intermediates that are isolated and then reprocessed due to maintenance activities or upset conditions?
• What are the reporting responsibilities for an importer if the supplier does not agree to be a joint submitter?

As the reporting period nears we will be taking a careful look at the rationales and explanations provided in the Preamble to the Final Rule as the buck stops with the final rule as published.

If you need guidance for the EPA TSCA 2012 CDR Submission, Emilcott offers three 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. Register for our free Dec 6 webinar:  Do You Understand TSCA 2012 CDR Requirements?

Paula Kaufmann

If Company A contracts with Company B to manufacture more than 25,000 lbs of a CDR-reportable chemical in 2010 and 2011, which company should report the chemical substance on their 2012 CDR submission?

The TSCA CDR Rule includes specific information that addresses reporting for chemicals that are toll manufactured: The definition of “manufacture” includes a description of the issue of toll manufacturing or “co-manufacturing” (40 CFR 711.3 Definitions).

When a chemical substance, manufactured other than by import, is:

(1) produced exclusively for another person who contracts for such production,

and

(2) that other person specifies the identity of the chemical substance and controls the total amount produced and the basic technology for the plant process, then that chemical substance is co-manufactured by the producing manufacturer and the person contracting for such production.

So, for the purposes of CDR submissions, the EPA considers both Company A (the person contracting production) and Company B (producing manufacturer) to BOTH be the manufacturers (co-manufacturers) and both the contracting company and the toll manufacturer are liable if no report is made.

So, back to the original question: 

WHICH company is required to report the chemical production?

Answer: Either, but just one.

And a follow-up question:

What will be considered the SITE for the production if the contracting company reports the chemical volume?

Answer: It doesn’t matter WHICH company reports, the SITE of production is that where it is physically manufactured (40 CFR 711.3 Definitions).  The CDR Form U accommodates a “Parent Company” name and location (Form U Section 1.A) AND “Site Information” (Form U Section 1.B.). This format will allow the contracting company to report a chemical produced at the toll manufacturer’s site.

The EPA does not want both to report (referred to as “duplicative reporting”) and, as such, requests that the contracting company and the toll manufacturer should agree on who will submit a CDR for specific sites where the chemical is produced (40 CFR 711.22 Duplicative reporting). For those who are not sure who is going to file (Company A or B), we suggest that you determine as quickly as possible who will have this responsibility and how costs and responsibilities will be shared (or not). And, determine what will happen if the CDR is incorrectly or not filed by the responsible company. This division of responsibility has the potential to be a problem so addressing it early will allow enough time for the gathering of information and reporting.

If you have additional TSCA questions, please register for our Free TSCA Information Webinar on Dec 6 which will include an open Q&A session or contact Emilcott directly for assistance.

Recently the National Institute of Occupational Safety and Health (NIOSH) commissioned a survey of the Occupational Safety and Health workforce and published their findings in a document called the National Assessment of the Occupational Safety and Health Workforce.

NIOSH reports that the need for OSH professionals will greatly outweigh the supply in the very near future.  If you minored in economics, like me, then this is a very easy concept of supply versus demand: as more OSH professionals are needed, fewer are beginning OSH careers AND a large proportion of the OSH profession will soon be retiring en masse.  Here are some excerpts from the Executive Summary of the survey:

“The survey shows that currently there are over 48,000 OS&H professionals in the U.S. workforce across the nine disciplines of interest to this study: The composition of the current OS&H workforce is primarily safety professionals (59%), followed by industrial hygienists (15%). The other major disciplines represented in the survey data were occupational health nursing (9%) and occupational medicine (3%).”

“Employers expect to hire over 25,000 OS&H professionals over the next 5 years, needing to fill an average of just over 5,000 positions per year;”

“Employers expect about 10 percent of safety professionals to retire within the next year; for the other OS&H professions the retirement projections are lower. “

“The workforce is graying, more among occupational physicians and occupational health nurses than safety and industrial hygiene professionals; however, we estimate that a large number of OS&H professionals in these disciplines are over the age of 50.”

Now as an OSH professional in the middle of her career my first thought on seeing this, of course, is “YAY! JOB SECURITY”!  Perhaps I can even name my salary…ahh, the bliss we all look for in a career.  But then the reality hits you a little harder when you think about what the lack of OSH professionals means not only for businesses, worker safety, and public safety but also the impact it will have on our family of OSH professionals.  We are already such a small community and we rely on each other as mentors, sources of inspirations/ideas, and friends.

So as much as I would like to name my own salary, I’d rather not have that luxury if it means losing this OSH community.  Here are a few ideas that we all can do to help us bring in new blood to our OSH family and strengthen the backbone of Public and Occupational Safety and Health in the U.S.

• Pass the word to the younger generation — visit your kid’s (or any kid’s!) school on Career Day or Science Day and talk about what you do.  Local schools are actively seeking professionals in scientific fields to model for their students.  (Be sure to bring some cool equipment with you!)
• Look for local youth groups, especially those who focus on young people from underprivileged families or communities.  These young people may not be aware of careers that involve environmental work or public health which may also benefit their communities.
• Hire or inspire a veteran returning from Iraq or Afghanistan to enter the OSH field.  Most returning members of the military have great leadership and organizational skills and are instinctively looking out for unsafe situations.  Plus they will be fearless even when faced with a toolbox safety talks for dozens of half-asleep, grouchy construction workers!
• Obtaining financial aid for OSH programs has been cited as a barrier for a lot of people going into the field so also pass along information or tips about NIOSH Training Grants that provide financial support for many academic programs in the OSH field. And, please support scholarship programs offered by professional organizations such as the ASSE and its local chapters. If you have an annual giving plan, why not support your own very important industry?
• Know someone in need of a job or career?  Point them in the direction of an OSH career by talking about the wide range of degrees and certificates in our field.  These added qualifications range from full-on college degrees to focused training in very specific OSH sectors depending on their interest and undergraduate achievement.

Degree Programs

Check out EHSCareers.com Resource Center for a great listing of college/university programs or look at these:

• My alma mater, Rochester Institute of Technology, has individual or combined Bachelor/Master Programs in the College of Applied Science and Technology
• University of Medicine and Dentistry of New Jersey offers degrees and certifications through their School of Public Health
• CUNY School of Public Health at the Hunter College
• North Carolina Agricultural and Technical State University’s Bachelor of Science in Occupational Safety and Health
• Columbia Southern University Online Bachelor and Master’s Degrees
• Slippery Rock University Public Health Programs

Certificate Programs

Emilcott EHS professionals have achieved many certificate-driven designations such as CHMM (Certified Hazardous Materials Manager), CIH (Certified Industrial Hygienist), CSP (Certified Safety Professional), PE (Professional Engineer), CHMP (Certified Hazardous Materials Professional) and CHST (Construction Health and Safety Technician).  These certifications and more are offered through universities, online programs, professional organizations and OSHA Training Centers.  Here is a list of some common and industry-recognized certification boards:

• The American Board of Industrial Hygiene certifies professionals in the practice of industrial hygiene.
• The Board of Certified Safety Professionals certifies professionals within several designations – all related to safety in the workplace. >
• The Institute of Hazardous Materials Management offers several professional certifications that demonstrate various levels of knowledge, expertise, and excellence in the management of hazardous materials.
• The Board of Environmental Auditor Certifications certifies four designation of EHS professionals which demonstrates the competency, professionalism, and ability of EHS auditors.
• The American Board for Occupational Health Nurses (ABOHN) an independent nursing specialty certification board and is the sole certifying body for occupational health nurses in the United States and awards four credentials:  Certified Occupational Health Nurse (COHN), Certified Occupational Health Nurse – Specialist (COHN-S), Case Management (CM), and Safety Management (SM).

Like any educational degree, use caution before pursuing any online certificate program from a private business or school as they may not be seen as valid education by many employers.  If you are unsure, ask your own supervisor or HR department for guidance before enrollment. There are many certificate programs developed for  supervisors already working in industry, such as the California State University Dominguez Hills certification program Occupational Health & Safety for Managers and Supervisors. See if your local college offers something similar. OSHA’s website provides information on their Training Centers but also has additional OSH degree and certificate program information. And, a comprehensive directory of possible certifications related to EHS professionals is available from the National Environmental, Safety and Health Association.

Know Your EHS Options and Get Started

Whether you are considering a new career in Occupational Health and Safety or you are looking for a next step in your H&S career, there are many options available for all levels of health and safety professionals from technicians in the field to researchers developing new technologies.  A helpful guide for all levels of current and future health and safety professionals is available through the Board of Certified Safety Professionals (BCSP).

At Emilcott, even before the study came out, we could see that the local pool of EHS professionals isdwindling and aging. In response, we have instituted a progressive mentoring program to move recent college graduates into the field, we support advanced degrees and certifications by our staff, we are active in our local chapter, we volunteer at school career day presentations, and were recently featured in a career choice video by the Wall Street Journal.

As a health and safety professional, what are you doing to bring fresh faces into our peer group? As an employer, have you instituted formalized plans to recruit and develop your staff? And, as a peer, how are you reaching out into the community to ensure that this profession remains healthy and growing?

TSCA questions are pouring in and we are responding.  To ensure that the information is available in a reasonable (and non-overwhelming) way, Emilcott has created a TSCA resource section of our web site for centralizing all kinds of intelligence, notifications, links, and summaries about Toxic Substance Control Act (TSCA) 2012 Chemical Data Reporting (CDR).

All these pages (just click on the headers) are available from the Emilcott Home page but we suggest you bookmark the pages that are most relevant and don’t forget to register for our December 6^th Free Webinar!

Emilcott TSCA Resource Center

The TSCA Resource Center has moved from the Emilcott home page to a new page – lots of information including all our TSCA-related EHSwire blogs (CDR and IUR) and EPA Chemical Data Reporting Links, EPA New Chemicals Links, and EPA Import/Export Links. This page will stay updated so that you have a one-stop location for all TSCA information. If you have specific issues you’d like to see addressed here, please let us know.

Free EMILCOTT TSCA 2012 CDR Webinar (Save the date for Dec 6^th.)

If you are wondering about the 2012 changes and how they will affect you, this FREE webinar is for you.  We will review the CDR requirements for 2012 as well as discuss some of the legal issues related to the standard of “known to or reasonably ascertainable by” for processing and use information and the upfront Confidential Business Information (CBI) substantiation. Developed for corporate attorneys, EHS managers, and regulatory affairs and environmental staff, the webinar will include an open-ended Q&A at the end so feel free to sign up, listen in and fire away. And, yes, of course, invite your co-workers and industry associates.

Emilcott TSCA-related Services

As we have seen with the change from IUR to CDR, compliance with TSCA regulations has become more challenging as companies must respond to increased regulatory activity and new information requests. As the EPA is really buckling down on enforcement, it’s certainly much smarter and less expensive to do it right the first time. If you need guidance, oversight, Form U filing help or more, just ask Emilcott.

EPA Violations for TSCA Non-compliance

Yes, every company wants to be in compliance – it’s much better to be on the good side of the EPA, right? However, TSCA regulations and filings are tricky, and it’s easy to misstep even when you’re trying to do the right thing. If you end up with a compliance violation and need some assistance, oversight or hand-holding, check out Emilcott’s services here. We have helped several companies reduce their fines by working with the EPA to demonstrate good will and a plan to get into compliance…quickly!

Free TSCA Newsletter

Get TSCA information delivered right to your email in-box – a quick subscribe!

More TSCA Information is Coming

As Emilcott continues to field a wide-range of questions from our clients and other TSCA-affected companies, we will post our responses through blogs on EHSwire and publish them in our TSCA Newsletter. If you have questions or needs specific to your organization, do not hesitate to contact me directly – a teamwork approach can transform TSCA compliance from dread and uncertainty to an interesting challenge!

How are you studying and keeping up to date with the changes in TSCA reporting for 2012? Are you signed up for the Emilcott TSCA newsletter? Have you registered for the Emilcott webinar on Dec 6^th?  Do you have any TSCA questions that you would like us to include in our blog and newsletter?