Environmental Data Issues
For more information or updates, please contact Dan Moss.
EPCRA: TRI Burden Reduction Revisions
Most Recent Status
On April 21, 2009, EPA finalized a rule that modified Form A eligibility (in order to comply with the Omnibus Appropriations Act of 2009 (which had been enacted on March 11),) For PBT chemicals, the final rule eliminated Form A eligibility for those chemicals listed at 40 C.F.R. section 372.28. For non-PBT chemicals, the final rule reinstated the 500-pound annual reporting amount (the total of releases and other waste management) and 1,000,000 pounds manufactured, processed or otherwise used Form A eligibility threshold in effect prior to January 22, 2007. This included the releases and waste management activities (Section 8.1 through and including Section 8.7) which are counted against the 500 pound threshold criterion.
EPA has attempted to reduce toxic release inventory (TRI) reporting burdens. SOCMA supported this effort and advocated that the proposed rule take comment on all options, including alternate year reporting and expansion of the Form A. A proposed rule on expansion of Form A eligibility was issued in the Federal Register in October 2005, as well as an Advanced Notice for Proposed Rulemaking on alternate-year reporting. The final TRI Rule was announced in December 2006. It expanded eligibility for the use of Form A in lieu of Form R by TRI facilities.
EPA Sector Program
EPA ended the program in 2010.
EPA's policy office developed an industry sector program to learn the unique issues of several industry sectors. SOCMA was involved in this effort beginning in 1996 and successfully obtained the attention of EPA on issues specific to our industry. As part of this program, EPA created for our sector an "EMS Guide for the Specialty Batch Chemical Manufacturing Industry," which was used for member performance improvement efforts. This guide saved SOCMA $40,000. EPA also developed for SOCMA a "Voluntary Programs Guide for the Specialty-Batch Chemical Manufacturing Sector." Furthermore, the program allowed SOCMA's concerns to gain increased visibility and helped SOCMA cultivate a positive relationship with EPA.