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2016 has been full of surprises but it is never good to be surprised when it comes to annual regulatory reporting! There are many things that we can do to minimize surprises and last minute scrambling.  The time to start the process is in the beginning of January 2017.

First – identify the regulatory submissions required for your organization and the deadlines for filing. These include submissions of the EPA Community Right to Know (CRTK) Survey and the Hazardous Waste Biennial Report (or Annual for some states) which are due March 1^st. Also on the horizon are the EPA Toxics Release Inventory (TRI) and the New Jersey Release and Pollution Prevention Report (RPPR) both due July 1^st.

The compilation and reporting process is less stressful and yields better results if it is started early and a strategy is developed with deadlines in mind.  Waiting until the last minute not only increases the potential for making mistakes, it is sometimes hard to get the submission through due to high volume of users on the same electronic filing system.

Here is my personal January 1^st kick-off list that should make the time-consuming process of CRTK and TRI reporting easier to handle….

Download the checklist e-book here!

1)      Start requesting and gathering all the information needed for these submittals.

1. 2016 purchasing records of the chemicals you are reporting
2. 2016 production logs where these chemicals are used
3. 2016 waste information
4. 2016 recycling information for any reported chemicals that were recycled
5. 2016 air emission inventory

2)      Develop and write down a comprehensive set of due dates so that you have time to review information as it comes in. If the requested data is late, have a plan to follow up or find another source because the deadline is not going to change!

3)      Review the rules early to avoid unpleasant surprises.

• Addition of NPEs Category (Proposed in November 2016): On November 16, 2016, EPA proposed a rule that would add a nonylphenol ethoxylates (NPEs) category to the Toxics Release Inventory (TRI) list of reportable chemicals. NPEs are nonionic surfactants used in adhesives, wetting agents, emulsifiers, stabilizers, dispersants, defoamers, cleaners, paints, and coatings.. https://www.epa.gov/toxics-release-inventory-tri-program/addition-npes-category-tri-list-proposed-rule
• Addition of Hexabromocyclododecane (HBCD) Category (Proposed in June 2016): On June 2, 2016, EPA proposed a rule that would add a hexabromocyclododecane (HBCD) category to the Toxics Release Inventory (TRI) list of reportable chemicals with a 100-pound reporting threshold. HBCD is a brominated flame retardant found in the environment, in wildlife, and in humans. https://www.epa.gov/toxics-release-inventory-tri-program/addition-hbcd-category-tri-list-proposed-rule

4)      Allow time for anomalies and additional fact-finding. Reported amounts from different sources may not match. If you find that is the case, it is your job to figure out why and that always adds more time to the already challenging process.

Emilcott’s clients depend on our environmental knowledge and organizational capabilities to gather the required information on time and give them fair warning if there is trouble ahead.  My best advice for successful reporting-don’t wait until the last minute.  Much like filing your income taxes on April 15^th, waiting until February to gather the information for the CRTK or starting in June for the TRI will be stressful and could result in costly errors. So, what am I doing today?  Like Santa, I’m checking my own list twice!

Have you been meeting the CRTK and TRI deadline? If yes, can you offer additional advice or do you have particular steps that you take to get the submission process rolling?

There are no federal workplace safety rules that prohibit portable electric space heaters in the workplace and statistics regarding commercial property damage caused by space heaters are not readily available. However, the U.S. Consumer Product Safety Commission estimates that more than 25,000 residential fires every year are associated with the use of space heaters—resulting in more than 300 deaths. In addition, an estimated 6,000 people every year receive emergency room care for burn injuries associated with contacting the hot surfaces of room heaters, mostly in non-fire situations.

So, as the cold weather sets in, employers may be considering if they should permit portable space heaters or actually discourage their use—even outright ban them. However, some work areas can just be cold. This is a frequent problem with older buildings or those areas near entries or doors.  Adding to the challenge, there are many employees with medical conditions that require extra warmth above what is normally considered comfortable and a space heater can fulfill that accommodation without heating up everyone else’s workspace.

The good news—like so many other hazards, portable space heaters can be used safely if proper care and precautions are implemented. Any employer permitting the use of portable space heaters should highly consider a written policy to spell out exactly what is proper care and sufficient precautions. It could possibly prevent fires, injuries and even death.

Firstly, OSHA rules do require that electrical equipment must be used according to manufacturer specifications on the unit’s label and in the user manual. Therefore, only employer-purchased and issued space heaters with adequate safety features should be used.  Generally, regardless of the types of space heaters, the following applies:

• Choose only thermostatically controlled heaters to avoid wasting energy or overheating
• Most heaters come with a general sizing table, so select heaters of varying sizes to fit the size of the areas that needs heating
• Position heaters on a level surface away from foot traffic
• All space heaters must be kept away from any combustible material

• Heaters should have a tip-over automatic shut down feature and a grounded three-pronged plug

• Require that space heaters always be turned off when the area is not occupied—possibly unplugged at night
• Plug heaters directly into a wall outlet and in plain sight
• Remind employees that nothing should ever be placed on top of or touching the space heater
• Heaters missing guards, control knobs, feet, frayed cords, or otherwise damaged must be taken out of service
• Discontinue use of the heater if the heater causes the electrical circuit breaker to trip

It is not recommended that unvented combustion space heaters, such as those fueled by propane, natural gas, and kerosene, be used for heating inside areas. They introduce unwanted combustion products into the environment—including nitrogen oxides, carbon monoxide, and water vapor—and deplete air in the space. Check for local regulations banning unvented kerosene and natural gas heaters.

Office Safety is covered under the OSHA General Duty Clause. Good office “housekeeping” and safety policies can prevent injuries. If you have questions about office safety policy, Emilcott can help.