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10/29/2013

Scary Stories of Noncompliance

As Halloween approaches, you are probably hearing a lot of scary stories. You may enjoy these tales of terror, but if you are not careful with how you manage your facilities, you may find yourself in a scary story of your own...

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10/08/2013

EPA Programs You May Not Know About

Most Americans are familiar with flagship U.S. EPA’s programs like the Clean Air, Clean Water, and Safe Drinking Water Acts. EHS managers and industry professionals know that in addition to these high-profile programs, the EPA also regulates hazardous waste under the Resource Conservation and Recovery Act (RCRA), chemical manufacturing under the Toxic Substances Control Act (TSCA), and...

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09/10/2013

Risk and Reaction: Reporting and Recordkeeping Under TSCA

When we talk about the Toxic Substances Control Act (TSCA), we often talk about the inventory reports chemical manufacturers, processors, and distributors must submit to the EPA. In addition to requiring these inventory reports, TSCA also includes reporting and recordkeeping standards for two specially identified situations: Companies must report to the EPA on any...

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08/13/2013

What is EPA Planning for 2014?

As we pass the mid-point of 2013, industry starts looking ahead to the coming calendar year, and so does the Environmental Protection Agency (EPA). Listed below are some of the major initiatives EPA is planning for 2014, pulled from various sources, including the Spring Regulatory Agenda, EPA’s website, and the Agency’s 2014 budget proposal...

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07/30/2013

OSHA Versus EPA On Accidental Releases

Events such as the West, Texas fertilizer plant explosion in April and the explosions at two manufacturing facilities in Louisiana in June have renewed interest in the regulations that have been established regarding accidental release prevention and facility security...

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07/24/2013

Spring 2013 Regulatory Agendas Now Available

On Tuesday July 23rd the Federal Register published a series of notices announcing the availability of the Spring 2013 Semiannual Agenda of Regulatory & Deregulatory Actions. The complete agendas were posted to reginfo.gov on July 5th. Tuesday’s Register contains excerpts and summaries of the full agendas to comply with the Regulatory Fexlibity Act...

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07/22/2013

EPA Updates List of TRI Facilities

On July 18, 2013, EPA issued both a Proposed Rule (78 FR 42910) and a Direct Final Rule (78 FR 42875 h) to require businesses to refer to the 2012 version of the North American Industry Classification System (NAICS) when filing their Toxic Release Inventory (TRI). This change applies to TRI reports due...

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07/10/2013

Understanding Superfund Discovery and Remediation

On May 21, 2013, EPA announced the addition of 9 hazardous waste sites to the National Priorities List (NPL) and a proposal to add 9 more. This brings the total number of sites listed on the NPL to 1,685. According to EPA, 68% of those sites (1,145) have cleanup remedies in place...

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06/11/2013

Release Reporting Requirements—CERCLA vs. EPCRA

The EPA oversees two major reporting programs aimed at facilitating immediate response and long-term cleanup of hazardous substances released into the environment. The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)—also known as Superfund—was enacted in 1980 and authorizes the Federal government to...

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05/14/2013

“Form R” Deadline Approaching Fast

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...

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