In our以前的博客电竞app竞猜in this series, we discussed how to leverage the requirements of environmental reporting into better outcomes for your business. In this post, we will discuss in three sections how to prepare for environmental reporting for Tier II (SARA Section 311/312), TRI (SARA Section 313), and hazardous waste. We will be talking in general terms – as each state or local government may have specific reporting requirements – and will briefly cover the regulatory background, reporting applicability, steps for determining what to report, reporting tips, and content of these three reports.
Tier II报告（SARA第311/312节）
Regulatory Background
Title III of the Superfund Amendments and Reauthorization Act (SARA), also known as the Emergency Planning and Community Right to Know Act (EPCRA), is intended to provide emergency planning agencies and local governments information about chemical hazards present in their communities. Under EPCRA, the US Environmental Protection Agency (EPA) created a list of extremely hazardous substances (EHS). In addition, EPCRA provides authority for state and local governments, and even citizens, to bring civil actions against companies that violate the requirements of EPCRA.
谁需要报告？
在萨拉的第311和312节中讨论了Tier II报告。在这些部分下，如果设施在其设施上有EHS或危险或有毒化学物质，则他们必须提交提供这些化学品列表以及安全数据表（SDSS）的副本的报告。报告将于3月1日期间到该州。
Under EPCRA, hazardous or toxic chemicals are those which have a SDSs and pose a physical or chemical hazard. The threshold reporting quantities for EHS varies by chemical and can be as low as one pound. The threshold reporting quantities for all other hazardous or toxic chemicals is 10,000 pounds.
Steps for Determining What to Report
Step 1: Compile a list of materials/chemicals you have at your facility to determine which of these materials/chemicals are considered hazardous or toxic and are EHS. The SDSs and EPA’s list of EHS can help you determine this.
第2步：确定您在现场使用的每种材料/化学物质的最大金额。将此量与阈值报告进行比较，以确定您是否需要执行Tier II报告。购买和使用记录对这一步骤非常有用。
Reporting Tips
确定您需要报告的内容可能会直截了当，但是在您编制可报告材料/化学物质的列表时有几件事需要考虑。例如，当您订购其他材料时，您可能在短时间内有超过10,000磅，或者您的设施订购了几个地点或卫星办公室的材料，您可能有超过10,000磅的材料，直到它发货关闭那些其他地方。如果您一天有超过10,000磅，则符合报告要求。
Another thing to consider as you compare your list of materials is the portion of the material that is hazardous, toxic, or an EHS. For example, if the material contains chemical A and other non-toxic materials, but the concentration of chemical A is 50%, then if you have 10,000 pounds of the material, you only have 5,000 pounds of chemical A. A close look at the SDSs is important to determine the ingredients of each material/chemical and the percent concentration of each ingredient.
报告内容
这个练习结束时,你应该机智h a list of materials/chemicals that have been present at your facility for at least one day and exceed the threshold reporting quantities. This is the information that needs to be reported to your state agency. For many states, in addition to the general Tier II reporting, you need to provide a list of all your SDSs to the local emergency response committee (LERC), usually your local fire department. For some states, when you file your Tier II report, the State provides the information to the LERC.
除了材料/化学品列表外，您还需要有关如何以及何处存储这些材料的信息。例如，罐，鼓或盒子中的材料是什么？储存在建筑物内外的材料吗？在一个特殊的区域？需要报告所有这些信息。
To help you understand the specifics of what your state requires, the EPA website haslinks对每个州的一级二级报告程序和要求。
TRI Reporting (SARA Section 313)
Background
Toxic Release Inventory, or TRI, is section 313 of SARA. TRI reporting is required each year by July 1, and tracks the management and use of certain toxic chemicals. TRI is a public tool, meaning that individuals can look to see what TRI reports have been filed in their area. The data is usually available to the public around October of each year.
谁需要报告？
Unlike Tier II reporting, where anything that poses any type of hazard is covered, TRI only covers a specific list of chemicals, but that list includes over 750 individually listed chemicals and 33 chemical categories. Another difference between Tier II and TRI is that TRI only applies to facilities involved in manufacturing, metal mining, electric power generation, chemical manufacturing, and hazardous waste treatment. In addition, to meet the criteria of TRI, the facility must employ 10 or more full-time equivalent employees.
Steps for Determining What to Report
Step 1: Compile a list of materials/chemicals you have at your facility like what you need for Tier II reporting.
Step 2: Determine the amount of each material/chemical that you manufacture (either as a primary product or byproduct), process, or otherwise use at your facility. Compare this amount to the threshold reporting quantities to determine if you need to do the TRI report. Purchasing, use, production, and disposal records are very helpful for this step.
Reporting Tips
Tri似乎比Tier II更简单，因为化学品列表更具体。然而，TRI报告阈值不是基于任何时间存在的化学物质的量，而是对制造，加工或以其他方式使用的化学品的总量。因此，除了购买和使用您可能已经收集的Tier II收集的记录，您还需要收集生产和处置记录。
请记住，TRI中化学物质的阈值报告量可能根据化学物质的使用方式而变化。例如，制造的化学物质的阈值可能与加工或以其他方式使用相同的化学物质来不同。因此，除了了解您的设施中有哪些化学品，您还需要注意您如何使用或生产这些材料。意思是，您是否制造它，是您处理的一部分，还是以其他方式使用？
For example, we assisted a facility that was evaluating whether they needed to report under TRI. They met the type of facility and number of employees threshold, so the last step was to identify all the materials at their facility. We determined that one of the two chemicals they used in a two-part foam packaging process was on the TRI list. They didn’t manufacture the material and it wasn’t used as part of their manufacturing process, it was only used for shipping their final product. Based on their usage, they needed to report because they met the “otherwise used” threshold for that chemical.
报告内容
请记住，对于TRI，您还需要报告释放了多少材料（是否通过卫生下水道或空气排放，回收或以其他方式处理）。您可以使用您保留其他监管程序的记录来满足此要求。例如，您可以使用空气排放库存报告中使用的记录和计算来确定您的TRI报告的空气排放。我们将更多地讨论我们的下一个博客中的空气排放量报告。电竞app竞猜
Hazardous Waste (RCRA)
Regulatory Background
Hazardous waste is regulated under the Resource Conservation and Recovery Act (RCRA) and the regulations govern hazardous waste identification, classification, generation, management, and disposal.
谁需要报告？
您通常需要获得危险的废物识别号码并在产生危险废物时报告您的活动。然而，具体的危险废物报告要求因国家而异。有些国家要求每次废物产生实体的年度报告，而其他国家只需要大量发电机每隔一年报告（两年期报告）。无论状态如何，危险的废物都有具体的处理和处置要求，我们不会在这里讨论。
Steps for Determining What to Report
Step 1: Identify your wastes
For hazardous waste reporting, you need to knowallthe wastes that your facility generates. This includes not only solid waste but also liquid or gaseous wastes. To evaluate whether your facility generates hazardous waste, you need to understand all wastes produced by all areas and processes, and how much of these wastes are generated monthly and annually. Records that would be useful for this step would be waste disposal records or manifests.
Step 2: Determine if your waste is hazardous.
Once you have your list of wastes, you need to evaluate each waste to determine whether it meets the definition of hazardous. Wastes can be determined to be hazardous because they are a listed waste, which means they are on a list of specific chemicals or wastes that are determined to be hazardous, or because they have a characteristic which makes them hazardous (like being flammable or toxic). Other wastes might be not hazardous but have special requirements for handling and disposal. These wastes are universal wastes or special wastes. There are different reporting requirements for those types of wastes.
Reporting Tips
For some wastes, you may want to collect your purchasing records. Perhaps as part of your manufacturing process your facility takes an x-ray of the product for quality purposes. This step would then likely generate waste developer or fixer, which is likely disposed of down a drain, rather than in a drum or other container. For these materials, the purchasing records would indicate how much developer and fixer you use each month.
Make sure to keep records of all your waste determinations, even if you determine that one of your wastes is not hazardous. If you are ever audited, this is one of the things the regulator will ask for.
报告内容
In addition to reporting how much waste you produced, you will also need to report where the waste went and how it was managed (such as burned for fuel, recycled, etc.). Your waste manifests should provide you with this information. Remember that what you need to report and how often you need to report will vary by state.
In Summary
For all of the situations discussed here, you need to keep records so you can document how you determined your reporting requirements. The evaluation will need to be reviewed annually for any changes in materials, chemicals, or quantities, as that can change your reporting requirements. With proper evaluation and preparation, environmental reporting can be straight forward. In our next blog in our three-part series, “Environmental Reporting – Clean Air Act & Clean Water Act”, we will discuss the requirements for reporting under those rules.
Braun Intertec has experienced consultants that can help you determine what reporting requirements apply to you and help you prepare and submit your environmental reports. Contact us for assistance or questions.