The deadline to submit your annual Toxic Release Inventory (TRI or FORM R) reports to the EPA is just around the corner on July 1, 2021. Before preparing these reports, you should ensure you are familiar with changes to reporting requirements for RY 2020.
The United States Environmental Protection Agency (USEPA) Hazardous Waste Generator Improvements Rule included a new notification requirement that will take effect in 2021 for small quantity generators (SQG) of hazardous waste. Be sure that you understand this new SQG Notification Requirement and how these changed will affect your state.
The United States Environmental Protection Agency (EPA) published the ﬁnalized amendments to the General Provisions that apply to the National Emission Standards for Hazardous Air Pollutants (NESHAPs) under section 112 of the Clean Air Act (CAA) in the Federal Registrar on October 1, 2020.
These amendments allow a source to reclassify to an “area source” (non-major) of Hazardous Air Pollutants (HAP)s at any time upon reducing its Potential to Emit (PTE) below 10 tons per year (tpy) of a single HAP or 25 tpy of all HAPs combined.
In 2019, the EPA added hazardous waste aerosol cans to the federal universal waste list, which allows generators to manage the cans with the less burdensome universal waste requirements. The final rule became effective on February 7, 2020, and applies to those who generate, transport, treat, recycle or dispose of hazardous waste aerosol cans. Under the universal waste rule, generators and handlers can store cans for a year and manage all aerosols together provided they are punctured and drained of any free liquid. (Note that the collected liquid from draining the aerosol cans will likely be considered hazardous waste.)
Per- and polyfluoroalkyl substances (PFAS) are a group of man-made chemicals that have been the subject of new regulations in recent years. Beginning with the 2020 reporting year, 172 new PFAS chemicals have been added to the list of reportable chemicals under Toxic Release Inventory (TRI) program. Facilities that manufacture, process, or use 100 pounds or more per year of any of the listed PFAS chemicals must include those chemicals in their annual TRI report due July 1, 2021.
The Environmental Protection Agency (EPA) has released its finalized reporting requirements and amendments to the 2020 Toxic Substance Control Act (TSCA) Chemical Data Reporting (CDR). They have also announced that the submission period has been extended once again from November 30, 2020, until January 29, 2021.
TSCA CDR requires U.S. manufacturers and importers of certain chemicals to report information on these chemicals to the US EPA. In March of 2020 changes were finalized for the 2020 CDR submission requirements.