December 9, 2016
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 1st. Also on the horizon are the EPA Toxics Release Inventory (TRI) and the New Jersey Release and Pollution Prevention Report (RPPR) both due July 1st.
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 1st kick-off list that should make the time-consuming process of CRTK and TRI reporting easier to handle….
1) Start requesting and gathering all the information needed for these submittals.
- 2016 purchasing records of the chemicals you are reporting
- 2016 production logs where these chemicals are used
- 2016 waste information
- 2016 recycling information for any reported chemicals that were recycled
- 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 15th, 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?