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Toxic Release Inventory (TRI) Reminder! July 1st Deadline
As noted in previous newsletters, facilities required to annually report Toxics Release Inventory (TRI) which is based on a facility’s North American Industry Classification System (NAICS) Code and thresholds set by the EPA found in EPA’s software TRI-ME must be submitted by July 1st. Facilities must report release and other waste management information pursuant to Emergency Planning and Community Right-to-Know Act (EPCRA) Section 313 if they:(1) have 10 or more full-time employees; (2) are in a covered NAICS code; (3) and exceed any one threshold for manufacturing (including importing), processing, or otherwise use a toxic chemical listed in 40 Code of Federal Regulations (CFR) Section 372.65
It is very important to complete TRI reports in a complete and accurate manner. Contact PWGC today for assistance.
In addition, the EPA is hosting the TRI University Challenge. The TRI University Challenge aims to increase awareness of the TRI Program and data within academic communities; expose students to TRI data, tools, and analysis; and generate innovative programs, activities, recommendations, or research that improve the accessibility, awareness, and use of TRI data.
EPA is looking to academic institutions to help build a diverse portfolio of practical and replicable projects that benefit communities, the environment, academic institutions, and the TRI Program.
Fuel in sulfur limitations is covered in NYSDEC’s 6NYCRR Part 225. Per the regulations starting in July 2012, owners and/or operators of commercial, industrial, or residential emission sources that fire number two heating oil were limited to the purchase of number two heating oil with 0.0015 percent sulfur by weight or less. In July 2014, stationary combustion installations that fire distillate oil other than number two heating oil were limited to the purchase of distillate oil with 0.0015 percent sulfur by weight. Starting this July 1, 2016, owners and/or operators of any stationary combustion installation that fires distillate oil including number two heating oil are limited to the firing of distillate oil with 0.0015 percent sulfur by weight or less on or after July 1, 2016.
Note that per the NYSDEC distillate oil is defined as “A fuel oil consisting of distilled fractions and having a kinematic viscosity of 5.8 centistokes or less at 100 degrees Fahrenheit. This includes ASTM grade numbers 1 and 2 fuel oil, ASTM grade numbers 1-D and 2-D diesel fuel oil and proposed ASTM grade numbers 1-GT and 2-GT gas turbine fuel oil.”
Additionally, owners and/or operators of any stationary combustion installation firing residual oil were limited to firing residual oil with a sulfur content 0.30 in New York City and 0.37 in Nassau, Rockland and Westchester Counties by July 2014. Owners and/or operators of any stationary combustion installation are limited to the firing of residual oil with a sulfur content of 0.5 in Suffolk County, Towns of Brookhaven Huntington, Islip, Smith Town, Babylon, and Eerie and Niagara Counties on or after July 1, 2016.
Hazard Communication Standard (HCS) Updates
OSHA modified the Hazardous Communication Standard (HCS) to adopt globally harmonized system (GHS) to improve safety and health of workers through more effective communication on chemical hazards. By June 1, 2016 all employers that use, handle or store hazardous chemicals must update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.
The three major areas of change are in hazard classification, labels, and safety data sheets.
Hazard classification: The definitions of hazard have been changed to provide specific criteria for classification of health and physical hazards, as well as classification of mixtures. These specific criteria will help to ensure that evaluations of hazardous effects are consistent across manufacturers, and that labels and safety data sheets are more accurate as a result.
Labels: Chemical manufacturers and importers will be required to provide a label that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must also be provided.
Safety Data Sheets: Will now have a specified 16-section format.
The GHS does not include harmonized training provisions, but understanding that training is essential to an effective hazard communication approach the revised HCS requires that workers be re- trained within two years of the publication of the final rule to facilitate recognition and understanding of the new labels and safety data sheets. Note OSHA required employees to be trained on new label elements (i.e. pictograms, etc.) and SDS format by Dec 1, 2013 with full compliance with the final rule in 2015.
PWGC has provided this newsletter solely for informational purposes; we make no warranties or certifications for a specific matter. If you require further information on a subject of this newsletter, would like to discuss your particular circumstances or would like to provide feedback, please feel free to reply directly to this email.