TSCA Chemical Data report
EPA’s Toxic Substances Control ACT (TSCA) Chemical Data Reporting (CDR) rule requires manufacturers (including importers) to provide information on the chemicals they manufacture domestically or import into the United States. EQM chemical reporting team members assist clients with this reporting requirement. We identify the facility’s manufactured and imported chemicals for applicability (and any exemptions) and perform a threshold evaluation to determine if the reporting threshold of 25,000 lbs per year (or 2,500 lbs per year for TSCA action chemicals) is met. The next CDR submission period begins June 1, 2020 and covers information for calendar years 2016, 2017, 2018, and 2019. Reports are submitted online through EPA’s Central Data Exchange (CDX).
Toxic Release Inventory Reporting
Similar to Tier II reporting, EQM chemical reporting team members assist facilities with annual reporting of toxic chemical releases required under Section 313 of the federal Emergency Planning and Community Right-To-Know Act (EPCRA or R-T-K). Also known as “TRI” or “Form R” reporting, it requires annual reporting of releases of listed toxic chemicals if certain thresholds are met. The reports are referred to as Form Rs and must be submitted annually by July 1 for the previous calendar year. EQM assists with assembling chemical throughputs, performing the reportable chemical threshold evaluation, estimating environmental releases and off site waste transfers of the reportable chemicals, preparing the forms and documentation, and facilitating submittal by the facility through EPA’s online CDX system.
Tier II Inventory
EQM chemical reporting team members assist facilities with annual reporting required under Section 312 of the federal Emergency Planning and Community Right-To-Know Act (EPCRA or R-T-K). Also known as “Tier II” or “SERC” reporting, it requires reporting of hazardous and extremely hazardous chemical storage above certain thresholds by March 1 each year for the previous calendar year. The intent is to ensure that emergency planners, responders, and citizens know about hazardous chemical storage at facilities. EQM assists with assembling the material inventory, performing the reportable chemical threshold evaluation, identifying chemical hazards through SDS review, preparing the forms and maps, and submitting the entire reporting package on behalf of our clients.
Chemical Warfare Convention
EQM chemical reporting team members assist clients with applicability assessment and reporting required by the Chemical Weapons Convention regulations. The Bureau of Industry and Security Treaty Compliance Division oversees the regulations that require chemical production facilities that produce any of the listed chemicals above thresholds to declare that they produce the chemicals and then report production quantity annually. After the chemicals are declared by a facility, the Bureau reviews the information and may require regular facility inspections. EQM team members review chemical production processes to determine if the regulations apply and if so prepare the required notifications and reports for submittal by the client.
Department of Homeland Security (DHS) Chemical Facility Anti-Terrorist Standards (CFATS) were developed to prevent chemical-related terrorist attacks within US borders. EQM team members assist facilities that store the listed chemicals to determine if they store quantities above thresholds and, if so, what notifications must be made to DHS (e.g., electronic submittal of information through CFATS online reporting). DHS then determines if additional risk evaluation is needed to determine if more rigorous security measures are needed for the facility and will work with the facility on executing measures. EQM provides our clients with technical expertise and assistance throughout the entire DHS process and helps to ensure all requirements are fully met.
Risk Management Program
EQM air and safety team members assist clients with Risk Management Program (RMP) compliance. The RMP rule requires facilities that use listed extremely hazardous substances to develop a prevention and response program to address potential chemical releases with offsite impacts. The regulations have 3 program levels, depending on the chemical and the potential for offsite release. EQM staff assists facilities with the regulatory requirements for all program levels including Program 2 hazard review and Program 3 OSHA process safety management program development and auditing. Risk Management Plans must be updated and re-submitted to EPA every 5 years.