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EPA Adds 12 Chemicals to Annual EPCRA Reporting Requirements

In response to a petition filed under the Emergency Planning and Community Right-to-Know Act (“EPCRA”), EPA is adding 12 chemicals to the list of toxic chemicals subject to annual reporting under EPCRA and the Pollution...more

Environmental Notes - December 2022

EPA Proposes to Expand TRI Reporting Requirements for PFAS and Other Chemicals of Special Concern - EPA is proposing to add per- and polyfluoroalkyl substances (“PFAS”) subject to reporting under the Emergency Planning...more

New Approach: Proposed PFAS Regulation Erodes TSCA Exemptions

EPA’s proposed reporting and recordkeeping requirements for Per- and Polyfluoroalkyl Substances (PFAS) under the Toxic Substances Control Act (TSCA) may be notable for what they do not do. In particular, the proposal does not...more

OSHA Reporting and Recordkeeping for COVID-19 at the Workplace

Employers may be liable for failing to file incident reports and properly record employees affected by COVID-19 on OSHA 300 and 300A logs. If it can be shown the illness is contracted at work, OSHA may expect the illness to...more

Environmental Notes - January 2019

EPA recently released a final regional office realignment plan in response to President Trump’s March 2017 Executive Order 13781. That order required EPA and other federal agencies to improve efficiency, effectiveness, and...more

Final TSCA Inventory Notification Rule Issued

EPA has begun promulgating regulations to implement the Frank R. Lautenberg Chemical Safety for the 21st Century Act of 2016 (Act), legislation that makes significant changes to the Toxic Substance Control Act (TSCA). EPA...more

Hurricanes and Flooding: Surely EPA Regulations are Suspended?!

It seems to happen every year. A natural disaster disrupts fall football season, and interstates are full of evacuees gobbling up hotel rooms and squatting in the nearest safety zones. In those times, no one ever thinks of...more

Refrigeration Systems Targeted: Risk Management Plans and Release Reporting

Companies operating ammonia refrigeration systems are easy targets for EPA under a number of environmental programs. Recent history suggests release reporting under Section 112(r) of the Clean Air Act (CAA) and under the...more

EPCRA Section 313 Reporting: Frequent Questions

This is the second installment of frequently asked questions regarding Toxic Release Inventory (TRI) reporting under Section 313 of the Emergency Planning with Community Right-to-Know Act (EPCRA). As noted in our first...more

EPCRA 313 Reporting – FAQs

The Emergency Planning and Community Right-to-know Act (EPCRA) requires Form R reports to be filed with EPA each July 1 for each listed “toxic chemical” a facility manufactures or processes in excess of 25,000 lbs., or...more

EPA Denies Petition to Remove EGBE From List of TRI Form R Chemicals

Ethylene glycol monobutyl ether (EGBE) is a solvent used primarily in the production of paints, coatings, and metal and household cleaners. It’s also used in the production of other chemicals. Facilities that manufacture,...more

Environmental Notes - June 2015

In this Issue: - EPA Issues SIP Call to Eliminate SSM Defense - EPA and Corps Define “Waters of The United States” - Frequent Questions: EPCRA 313 - Generators Need to be Vigilant About TCLP Sampling...more

Frequent Questions: EPCRA 313

This is the third and final installment of Frequent Questions related to Form R Reports due July 1. The Frequent Questions are published by EPA or researched to aid compliance with this complicated regulatory program....more

FREQUENT QUESTIONS: Form R Part II

As the July 1 deadline for filing the Form R for your facility approaches, these additional Frequent Questions may assist your preparation. Question: For purposes of Section 313 reporting, is ammonium nitrate in a...more

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