Final Rule Alert: NPEs Added to EPCRA TRI Reporting
US EPA promulgated a Final Rule on June 12, 2018 to add a category for nonylphenol ethoxylates (NPEs) to the reporting requirements in Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA).
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.
Identify your site’s chemical inventory and release reporting responsibilities under EPCRA and CERCLA with the Superfund and Right-to-Know Act Regulations Online Course.
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.
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.
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.
Are you the go-to person for all things EHS at your facility? Understanding the air, water, and chemical regulations that apply to your facility will help you communicate clearly and confidently with your organization and better defend your business against costly fines, penalties, and future liability.
Lion’s Complete Environmental Regulations Workshop is presented nationwide and covers the critical elements of the major EPA programs that affect industrial facilities every day.
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.
Identify your site’s chemical inventory and release reporting responsibilities under EPCRA and CERCLA with the Superfund and Right-to-Know Act Regulations Online Course.
What Are NPEs?
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.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.
Does TRI Reporting Cover My Site?
To determine whether EPCRA Section 313 reporting applies to your site’s activities, you can ask yourself four questions.
- 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?
EPCRA TRI Reporting Thresholds
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.
Build Your EHS Management Credentials
Are you the go-to person for all things EHS at your facility? Understanding the air, water, and chemical regulations that apply to your facility will help you communicate clearly and confidently with your organization and better defend your business against costly fines, penalties, and future liability.Lion’s Complete Environmental Regulations Workshop is presented nationwide and covers the critical elements of the major EPA programs that affect industrial facilities every day.
Tags: chemical, chemicals, EPCRA, inventory, reporting and recordkeeing, TRI
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