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The EPA recently found a company in violation of the Emergency Planning and Community Right-to-Know Act’s (EPCRA) hazardous chemical inventory (also known as Tier II) and Toxics Release Inventory (TRI) reporting requirements and levied a penalty of over $160,000. Are you confident in your compliance with EPCRA reporting requirements? Now might be a good time […]
The EPA has issued a direct final rule—that is, an action for which there was no prior opportunity for public comment, and, in this case, one that is effective immediately—that appears to put an end to a 10-year dispute over whether air emissions from animal waste at farms should be subject to reporting under the […]
Our first environmental enforcement report for August 2018 has summaries of five recent cases—and two of them resulted in penalties of over $1,000,000. It’s an ongoing reminder of the importance of environmental compliance to an organization’s bottom line.
Q. Can you provide some guidance on how to satisfy the requirements of the Safety Data Sheet (SDS) information without revealing the names or Chemical Abstracts Service (CAS) numbers of the chemicals we use in our mixtures?
The U.S. Environmental Protection Agency (EPA) proposed what it calls the Hazardous Waste Generator Improvements on September 25, 2015. An extended comment period closed December 24, 2015. The Agency has received over 230 comments on the proposal. The Advisor reviewed a number of them and will give you the gist of what people are saying […]
Q. What are the regulations surrounding Hydrogen Peroxide, 50% solution? Is it considered an extremely hazardous substance (EHS)? What are the reporting requirements under EPCRA?
The federal Emergency Planning and Community Right-to-Know Act (EPCRA) was designed to enhance and, in many cases, build state and local governments’ emergency response and preparedness capabilities. EPCRA requires industry to provide information about certain chemicals and the quantities present at their facilities, so that state and local officials can plan for and respond to […]
Regulatory exemptions for farms are common throughout the major U.S. environmental statutes, including the Emergency Planning and Community Right-to-Know Act (EPCRA). But exemptions for farms do not apply to all requirements in the major reporting provisions of EPCRA.
#1. What Went Wrong A California-based poultry company with a facility in Kelso allegedly did not meet the deadline in 2013 for reporting chemicals stored at its facility. The company apparently failed to report that it stored over 500 pounds (lb) each of ammonia and sulfuric acid, and over 10,000 lb each of carbon dioxide, […]
In this case, a foundry coke manufacturer in northern New York State will pay $2.75 million for alleged CAA, CWA, and EPCRA violations—and that is just the fine. ‘Citizen Scientists’ Complained A critical point in this case is that federal and state inspections came in response to local citizen complaints. The community even did their […]