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“Form R” Deadline Approaching Fast

Posted on 5/14/2013 by Anthony R. Cardno

Under the Emergency Planning and Community Right-to-Know Act (EPCRA), Section 313(c), Toxic Release Inventory (TRI), or “Form R,” reporting is required on or before July 1 for any “designated facility” that manufactures, imports, or processes any of over 600 “toxic chemicals.” The chemicals subject to Form R reporting are found at 40 CFR 372.65, where they are listed alphabetically by chemical name and matched with a CAS number and an “effective date,” which is the date the chemical was added to the list. Most of the chemicals on this list have been there since January 1, 1987, when EPCRA became law.
 
The EPA has the authority to revise the list, including adding or removing substances and changing reporting thresholds, after taking into account certain specified factors. [40 CFR 372.3]
 
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Designated Facilities Must File Form R 
 
Designated facilities must complete the Form R “for each chemical that was manufactured, processed or otherwise used in quantities exceeding the toxic chemical threshold quantity during the preceding calendar year.” [EPCRA §313(a)]
 
For the purposes of Toxic Release Inventory reporting, “designated facility” is defined as:
 
  • Businesses operating under SIC codes 10, 12, 20-39, 4911, 4931, 4939, 4953, 5169, 5171, and 7389 (with some industry-specific exceptions);
  • All Federal agencies (per Executive Order 13148, April 22, 2000); and
  • Facilities with ten or more full-time employees or the equivalent in hours worked (20,000 hours worked by all employees).
Report on Chemicals Manufactured, Processed, or Otherwise Used
 
The threshold quantities for reporting do not change from chemical to chemical, but are based on what the facility does with the chemical:
 
  • Manufactured (produce, prepare, import, or compound a toxic chemical): ≥ 25,000 lbs. during the calendar year
  • Processed (preparing chemical, after manufacture, for distribution in commerce): ≥ 25,000 lbs. during the calendar year
  • Otherwise used (anything that doesn’t meet the preceding two definitions): ≥ 10,000 lbs. or more during the calendar year
[40 CFR 372.3]
 
Form R (officially called EPA Form 9350-1) and the instructions for completing the form may be obtained from EPA’s TRI Reporting Forms and Instructions Page.
 
Learn How EPCRA and EPA Rules Apply
 
Learn more about EPCRA and EPA’s other major programs at the Complete Environmental Regulations Workshop. Identify your core responsibilities under the Clean Air Act, Clean Water Act, Safe Drinking Water Act, FIFRA, TSCA, and more, as required for ISO 14001 certification.
 

Tags: EPA, EPCRA, reporting and recordkeeping

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