EPA Proposes Changes to EPCRA Section 312 Tier I and Tier II Forms Reply

On August 8, 2011, the Environmental Protection Agency (EPA) published a proposed rule that suggests changes to the Emergency Planning and Community Right-to-Know Act (EPCRA) Section 312 (Tier I and Tier II) reports (40 CFR 370).  The proposed regulations include additions and revisions to the Tier I and Tier II forms so the forms can be more useful to state and local agencies and better inform the public on the chemical hazards in their communities. Although the proposed regulations refer to Tier I and Tier II forms, most state and local authorities only require a Tier II form from facilities that trip reporting thresholds.

EPA proposes to add the following to Tier I and Tier II forms:

  • Add entries for the facility’s identification number under EPCRA 313 (Toxic Chemical Release Inventory – Form R reporting) and Clean Air Act Risk Management Programs, if applicable.
  • Add an entry for the number of occupants at the facility.
  • Add entries for the facility’s parent company name, address, and phone as well as the company’s Dun and Bradstreet number.
  • Add entries for name and contact information of the facility representative required under EPCRA Section 303.
  • Add entries for name, title, and phone number of the person knowledgeable or responsible for completing the information on the Tier II form.
  • Add an entry to indicate whether the facility is also subject to Extremely Hazardous Substance (EHS) notification requirements under EPCRA Section 302.

EPA is also proposing to revise the following existing entries currently on the Tier II form:

  • Revise the current range codes for maximum and daily average amounts of hazardous chemicals to narrower codes than the existing codes to be more useful to Local Emergency Planning Committees (LEPCs) for effective emergency response planning.
  • Revise the reporting of chemicals (i.e., pure chemicals versus mixtures) to make it more user friendly for state and local authorities by providing separate entries for pure chemicals and mixtures.
  • Revise the form to allow for description of the types of storage and storage conditions rather than using codes.

EPA is soliciting comments on the proposed rule until October 7, 2011.

Please contact Linda Swift at 508.970.0033 ext. 119 or lswift@capaccio.com with any questions you may have regarding these proposed changes to EPCRA 312 reporting.

ISO 50001 Standard Published Reply

You can now manage your energy conservation program or lower your greenhouse gas emissions by using a new international standard, ISO 50001.  This new ISO Management System Standard for Energy has all of the same “plan-do-check-act” provisions of the ISO 14001 Environmental Management System. 

To save on the cost required to implement and certify a new management system, some companies are choosing to instead integrate the key energy management features of the ISO 50001 standard into their existing ISO 14001 or ISO 9001 management systems. Also, if a customer is not requiring certification to this standard, companies can use the integration option to achieve certification to ISO 14001 while seeking “verification” of the use of the energy management components.  It is also possible to self-certify to the ISO 50001 standard through this integration option. 

Should you choose to implement or integrate the new ISO 50001 Energy Management System Standard, CAPACCIO can help you make decisions on the options you have regarding the use of this new international energy management standard and guide you through the process.

For more information, contact Wayne Bates at 508.970-0033 ext. 121 or wbates@capaccio.com.

DHS Proposed Rule for Ammonium Nitrate Reply

The Department of Homeland Security (DHS) has issued a proposed rule regulating the sale and purchase of Ammonium Nitrate.  The proposed rule was published in the Federal Register on August 3, 2011 and can be found at:

http://www.federalregister.gov/articles/2011/08/03/2011-19313/ammonium-nitrate-security-program.  

There is a comment period for this proposed rule that closes December 1, 2011. The proposed regulation establishes a registration program for sale and purchase of 25 lbs or more of ammonium nitrate.  Regulated entities will receive a registration number and will need to maintain transaction records and have procedures in place to promptly report theft. 

Although ammonium nitrate is mostly used in the fertilizer industry, this regulation highlights a more important topic for all chemical users.  With every new regulation, the ability for a company to quickly determine how much of a chemical a facility uses, stores, produces, or puts into a product is becoming more and more important.  In addition to being able to track the chemicals at your facility, to be proactive, it is also important to stay abreast of new or proposed regulations.  The next regulated chemical could be integral to your process and a change in the procurement, management, or use, could have major consequences for production.   This topic will be addressed in more detail in our upcoming fall newsletter.

For more information, please contact Travis Wheeler at 508-970-0033 ext. 115 or at twheeler@capaccio.com.

First Aid and CPR WWT Operator TCH Credits Reply

CAPACCIO has had a few inquiries from our clients asking if First Aid Classes and CPR classes can be used toward the 20 Training Contact Hours (TCH’s) that WWT operators are required to obtain in order to maintain their licenses.  We spoke with the MassDEP who confirmed that they are approved. When operators submit their license renewal forms, they are to include a copy of the card (both sides) issued to them upon completion. First Aid Courses (regardless of actual length in hours) are approved for 3 TCH’s, similarly, CPR courses are also worth 3 TCH’s.  Some companies are now offering combined classes where First Aid and CPR are covered in the same course and the participants are issued one certification card for both.  If the class is combined the operators can only obtain 3 TCH’s and not 6 as they would if they were to take the classes separately. If you have any questions, contact Josh Fawson at 508-970-0033 ext. 120 or jfawson@capaccio.com.