Preparing for 2012 Reporting Obligations

Posted on 11/29/2011 by James Griffin

Personally, the last month of the year usually means entry into the year–end holiday season. For EHS managers, this should also mean preparing your 2012 compliance calendars. These calendars will likely include various reporting obligations. While many of your reporting obligations and frequencies are site–specific (e.g., NPDES discharge monitoring reports and Clean Air Act Title V certifications), some events are more universal. In fact, some reporting obligations only come along every few years or may be new for 2012. As you prepare your calendars, please take into consideration the following reporting obligations:
February 1, 2012—June 30, 2012: Chemical Data Reporting (40 CFR 711)—While technically a new rule for 2012, the requirements at 40 CFR 711 replace the old chemical substance inventory update reporting (IUR) from 40 CFR 710. According to 40 CFR 711, any site that manufactured or imported a chemical substance (including chemical substances in mixtures) in 2011 in a quantity > 25,000 pounds must submit a chemical data report (CDR) to the EPA for that chemical substance. For the 2012 CDR submission, the report must include full manufacturing data for 2011 and production volume for 2010. The EPA requires that all CDR submission be electronically submitted using e–CDR software. For more information on the CDR, visit Note: If you have never submitted any electronic information to the EPA through its Central Data Exchange (CDX), then you will need to register with the CDX before submitting your CDR submission.
March 1, 2012: Hazardous Waste Biennial Report—A large quantity generator that who ships any hazardous waste off site must prepare and submit a copy of the Biennial Report to the EPA (or State agency) on March 1 of any even–numbered year (40 CFR 262.41). The report must cover the generator activities during calendar year 2011. For more information regarding biennial reporting, visit
March 1, 2012: Annual Hazardous Chemical Inventory Reporting (40 CFR 370)—This Emergency Planning and Community Right–to–Know Act (EPCRA) program applies to facilities that were required to prepare or have available any material safety data sheet per 29 CFR 1910.1200 and had any hazardous chemical, as defined under 40 CFR 370.66, at or above its reporting trigger at any time in 2010. Covered facilities must submit an inventory report to the state emergency planning commission, local emergency planning committee, and local fire department.
Currently, all states require the Tier II form and may require electronic submission. The EPA has just released the 2012 version of their electronic reporting tool, Tier 2 Submit. Note: California’s Business Plan requirements (19 CCR 2729.1), including hazardous chemical inventory reporting, fulfill the requirements at 40 CFR 370.
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March 31, 2012: Mandatory Greenhouse Gas Emission Reporting (40 CFR 98)—This reporting requirement applies to the facilities listed at 40 CFR Part 98. There are different thresholds, depending on the covered source, under Part 98. Several new facilities are subject to greenhouse gas emission reporting for the first time, based on 2011 activity (see the EPA Fact Sheet). To accommodate the rule’s electronic submission requirement, reporting facilities must use the EPA’s e–GGRT system.
On November 29, 2011, the EPA promulgated a final rule that made some technical corrections and clarifications to the greenhouse gas reporting rule. Included in this final rule was a one-time, six-month extension of the 2012 reporting deadline for facilities and suppliers that contain one or more source categories for which data collection began in 2011. These sources include: Electronics Manufacturing (Subpart I), Fluorinated Gas Production (Subpart L), Magnesium Production (Subpart T), Petroleum and Natural Gas Systems (Subpart W), Use of Electric Transmission and Distribution Equipment (Subpart DD), Underground Coal Mines (Subpart FF), Industrial Wastewater Treatment (Subpart II), Geologic Sequestration of Carbon Dioxide (Subpart RR), Manufacture of Electric Transmission and Distribution (Subpart SS), Industrial Waste Landfills (Subpart TT), and Injection of Carbon Dioxide (Subpart UU),or in Imports and Exports of Equipment Pre-charged with Fluorinated GHGs or Containing Fluorinated GHGs in Closed-cell Foams (Subpart QQ). For these sources, the deadline for 2012 reporting is moved from March 31, 2012, to September 28, 2012.
June 30, 2012: Hazardous Materials Registration (49 CFR 107, Subpart G)—Shippers or carriers who meet one of six triggers at 49 CFR 107.601 must register with the U.S. DOT annually and pay a fee.
July 1, 2012: Toxic Chemical Release Reporting (40 CFR 372)—Facilities listed in Part 372 with 10 or more full–time employees that manufactured, processed, or otherwise used one or more of nearly 600 listed toxic chemicals above the specified thresholds in 2011 must submit a report detailing the facility’s releases to the environment and pollution prevention efforts for that toxic chemical.
July 1, 2012: Safe Drinking Water Act Consumer Confidence Reporting (40 CFR 141)—Community public water systems must distribute a copy of the consumer confidence report on the water quality of the drinking water.
July 1, 2012: Polychlorinated Biphenyl (PCB) Annual Report (40 CFR 761.180(a))—All facilities using or storing at any one time at least 45 kilograms (99.4 pounds) of PCBs contained in PCB container(s), or one or more PCB transformers, or 50 or more PCB capacitors shall develop and maintain at the facility a written annual document log of the disposition of PCBs and PCB items.
It is important to remember that additional reporting under Federal and State requirements may also apply to your facility. Carefully review all of your facility permits and associated regulations to establish a comprehensive reporting calendar for your facility. 

Tags: Act, Air, Clean, Clean Water Act, EPCRA, reporting and recordkeeping, TSCA

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