Well you’re off to a great start! Just continue to take it one month at a time and set your individual daily goals to accomplish this plan and you will be totally amazed with what you have completed by the end of the year. Remember, we’re eating this Regulatory Elephant… ONE BITE AT A TIME! Keep chewing on it, get help where you need it, and you’ll be able to relax a little easier each month with the peace of mind of knowing that you have drastically decreased your environmental/safety exposure and provided a safer workplace for your employees.
Like we mentioned last time, given that many of the EPA related reporting requirements are loaded on the front end of the year and the preparation time to do it correctly can be extensive, our monthly plan will reflect a heavier focus on EPA related issues in the first three months. However, get through this month and we get to start on some safety stuff next month… Yeah! Well you may not be as excited as I am so fake it.
The first one’s easy, if you did your work last month… just get a pin and stick it!
OSHA Recordkeeping – You should already have posted OSHA’s Form 300A in a place where all employees have access to view. If you haven’t… just stick it! You need to keep it posted from February 1st to April 30th. Remember OSHA’s on the “warpath” on this one (
read article). If you need help and you didn’t watch it last month, I suggest that you watch our FREE video from
last month’s edition of the Regulatory Reminder.
SARA Title III, Emergency Planning and Community Right-to-Know Act (EPCRA) – You only have a few weeks left to get this completed. Listed above in the upcoming deadlines are the links and information to what you need to do to comply. We also have a fairly easy way for you to determine if this regulation affects you on the
Tier II page of our website.
Last month we recommended that you start gathering your current chemical inventory and maximum amounts. Now it’s time to sift through the chemical constituents that comprise your products (MSDS). These constituents will be defined on each MSDS as Chemical Abstract Service (CAS) numbers. You basically need to see in if any of the chemicals listed on the EPA’s Extremely Hazardous List (EHS) list are present at your facility. You can find the EHS list in the
EPA’s List of Lists. You will most likely have at least a few. If you do have some then you need to see if your quantities of that chemical exceed the listed Threshold Planning Quantities (TPQ). This process is very cumbersome if you have more than about 10 MSDS. Then it is compounded by the fact that you also need to get the aggregate amount of each chemical that falls on the EHS list… meaning that all the different products that contain an EHS chemical need to added together to make your total. You take the weight of each product multiplied by the chemical percentage to get each chemical weight. If your aggregate total meets or exceeds the TPQ for that chemical, then that chemical is required to be submitted on your Tier II.
Aside from the EHS chemicals, all other chemicals that you have on hand any given day that exceed 10,000 lbs (aggregative) also require a Tier II.
Most states require that you submit your Tier II’s via the EPA’s Tier II submit software. However, some states have their own variation of the software; therefore, refer to your state’s requirements to submit your Tier II’s by clicking
here. Prepare your Tier II report and submit on or before March 1st.
Annual / Biennial Hazardous Waste Reporting - Listed above in the upcoming deadlines are the links and information to what you need to do to comply. Prepare your reports and submit on or before March 1st.
Air Emissions Inventory (AEI) Reporting - Listed above in the upcoming deadlines are the links and information to what you need to do to comply. The deadline for AEI reporting for Title V Major and Minor Source facilities varies by state and possibly your individual permit. However, it appears that if your permit requires semi-annual reporting, those reports are typically due by January 31st and July 31st. For facilities that require only the AEI annual report, it is typically due by April 1st. We presume that if your facility has an air permit, you are most likely very aware of your deadlines.
If you’re looking for the easiest way to track your air permit
click here.
Don’t know if you need an Air Permit? You need to find out! - For those of you who do not know if you’re required to have an air permit, we strongly suggest that you go to your state’s environmental website to determine for yourself if you are required to obtain an air permit by clicking
here. Then, if you are still not sure, we suggest that you get some help to determine if you need one. We can evaluate if you need an air permit. If you do, we write it for you. If it is determined that you do not need one, we will provide you with the documentation to support those findings.
Click here to view the process.
Whether you do it yourself, use us, or someone else that is competent, we strongly suggest that you make that determination. As we mentioned in our last issue EPA is getting very serious about permit violators (
read article “EPA unleashes its cops to target these 10 trouble spots) and it is much better to be proactive rather than reactive.
Storm Water Runoff Permit and Annual Inspection Report - Listed above in the upcoming deadlines are the links and information to what you need to do to comply. This is a reminder for those that currently have a storm water permit that your annual inspection report is due every year. The deadlines to submit the annual inspection will vary by state. In many states it is due March 1st, however, in some states they are due January 31, so make sure you check your state’s requirements. It is also a reminder that your visual or analytical quarterly monitoring needs to be completed by March 31st. We know that some of you are required to monitor monthly, however, we will not be reminding you monthly because I’m sure that you have it on your calendar… right?
For those of you who have not filed your Notice of Intent (NOI) and developed your Storm Water Pollution Prevention Plan (SWPPP) or obtained an exemption, you should do so. EPA is getting very serious about this one also, as mentioned in the above article link. However, we will be covering that more in depth in our April edition in an effort to spread these tasks out a bit so your head doesn’t explode.
That’s if for this month’s edition… get crackin’ and we’ll see you next month.
Thank you for reading this month’s issue of the Regulatory Reminder! We hope you found it to be helpful and informative. We welcome all your comments, suggestions and any corrections that you see we need to make. All are very important to us, so if you have any… please let us know.