Federal EPCRA 313 Form R and Massachusetts TURA Form S Reports Due July 1 Reply

It’s that time of year again when companies are calculating thresholds for chemicals used in calendar year (CY) 2012 to determine if there are any chemicals manufactured, processed or otherwise used on-site that need to be reported under the US Environmental Protection Agency’s Emergency Planning and Community Right To Know Act (EPCRA) Section 313 and the Massachusetts Department of Environmental Protection’s (MassDEP) Toxics Use Reduction Act (TURA).

This is just a friendly reminder that there are a few changes for TURA reporting this year. MassDEP designated hexavalent chromium compounds and formaldehyde as Higher Hazard Substances (HHS )and lowered the threshold for reporting these chemicals to 1,000 pounds for calendar year 2012 (due July 1, 2013). It’s important that you take the time to review the guidance MassDEP developed for these chemicals. You may be surprised with some of the processes that you have to consider when determining thresholds for these new HHSs (e.g., fuel combustion, welding, formaldehyde based resins).

Also please note that zinc metal (without any fume or dust qualifiers) is back on the MassDEP TURA Chemical List. Zinc was erroneously taken off the list back in the late 1990’s. MassDEP has said they will not take enforcement against those companies who start reporting for zinc metal in this reporting year. Discussions are in progress at MassDEP as to the fate of zinc metal on the TURA Chemical List.
For more information on MassDEP guidance for hexavalent chromium compounds and formaldehyde please go to:

http://www.mass.gov/eea/docs/dep/toxics/laws/frmlguid.pdf
http://www.mass.gov/eea/docs/dep/toxics/laws/crviguid.pdf

If you need assistance with your reports or more information, please contact Lucy Servidio at 508.970.0033 ext. 114 or lservidio@capaccio.com or Travis Wheeler at 508.970.0033 ext. 115 or twheeler@capaccio.com.

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