Final Rule Alert: NPEs Added to EPCRA TRI Reporting
Commonly referred to as the Toxic Release Inventory, or TRI, program, Section 313 of EPCRA requires facilities in certain industries to report to EPA if they manufacture, process, or use certain hazardous chemicals in volumes that exceed regulatory thresholds.
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Nonylphenol Ethoxylates (NPEs) are nonionic surfactants—i.e., they reduce tension between materials, making them easier to separate—used in the manufacture of cleaning products, adhesives, wetting agents, paints, emulsifiers, lawn care products, personal care products, and detergents. NPEs are also used in water treatment, textiles, metal working, oil field operations, and pulp and paper mills.
What Are NPEs?
Because NPEs are often used in “down-the-drain,” household-type products, contamination has been found in the water, sediment, soil, and aquatic life. The chemicals have also been found in human breast milk, blood, and urine.
For a complete list of chemicals covered by this rulemaking, see EPA’s Final Rule in the Federal Register.
To determine whether EPCRA Section 313 reporting applies to your site’s activities, you can ask yourself four questions.
Does TRI Reporting Cover My Site?
- Is your facility’s primary SIC code on the EPCRA Section 313 list?
- Does your facility employ ten or more full-time equivalent employees?
- Does your facility manufacture, process, or use EPCRA Section 313 chemicals?
- Does your facility exceed any of the activity thresholds for EPCRA Section 313 reporting?
The EPCRA TRI reporting thresholds are typically 25,000 pounds for chemicals manufactured or processed and 10,000 pounds for chemicals “otherwise used.” For so-called “chemicals of special concern” listed at 49 CFR 372.28, the reporting thresholds are significantly lower.
EPCRA TRI Reporting Thresholds
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Tags: chemical, chemicals, EPCRA, inventory, reporting and recordkeeing, TRI
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