The deadlines for Tier II Reports, Biennial Reports, and OSHA 300 Logs are all fast approaching. Are you prepared to file all your necessary reports in time? It is important to take the time to carefully review your facility to determine your requirements for these regulatory reports.

1. Are You Prepared for the
Upcoming Regulatory
Reporting Deadlines?
Jarred Melvin
Senior EHS Consultant
Triumvirate Environmental

2. Meet Your Moderator
2
Nita Vaidya

3. 3
During this Webinar
✓ All lines will be muted.
✓ Communicate via the questions tab in your webinar panel.
✓ Unanswered questions will be responded to personally after the
webinar.
✓ Webinar recording and slides will be emailed to you tomorrow.

4. Jarred Melvin
Senior EHS Consultant
Triumvirate Environmental
4
Meet Your Presenter

5. Agenda
5
Tier II Reporting
Biennial Reporting
OSHA 300 Logs
Q&A

6. Tier II
6
History & Importance
What Qualifies?
Reporting

7. History of EPCRA
• Deadly chemical release from Union
Carbide pesticide plant in 1984 in Bhopal,
India
▪ Approximately 40 tons of methyl isocyanate
was released into the air
▪ Killed up to 5,000 people and injured 50,000
more
• Around the time of the Bhopal disaster
nearly 6,928 chemical accidents occurred
in the US over a 5-year period
7

8. History of EPCRA
• In November 1986, Congress passed the Emergency Planning
& Community Right-to-Know Act
• Major functions:
▪ Support emergency planning in response to chemical accidents
▪ Provide local governments and the public with information about
chemical hazards in their communities
8

9. Acronyms
9
• EPCRA – Emergency Planning & Community Right-to-Know Act
• LEPC – Local Emergency Planning Committee
• SERC – State Emergency Response Commission
• TPQ – Threshold Planning Quantity
• EHS – Extremely Hazardous Substance
• TRI – Toxics Release Inventory
• SARA – Superfuns Amendments & Reauthorization Act

10. Four Major Provisions of EPCRA
• Emergency Planning (Sections 301-303)
• Emergency Release Notification (Section
304)
• Hazardous Chemical Storage Reporting
Requirements (Sections 311-312)
• Toxic Chemical Release Inventory
(Section 313)
10

11. EPCRA Section 312
• Section 312 requires submittal of
annual (by March 1) Tier II Chemical
Inventory Reports to the SERC,
LEPC, and/or local fire department
11

12. State Emergency Response
Commission (SERC)
12
• Typically the state emergency
management agency
▪ Example: Massachusetts Emergency
Management Agency (MEMA)
• SERC is responsible for:
▪ Reviewing local emergency response plans
▪ Designating local emergency planning districts
▪ Appointing LEPCs for each district
▪ Supervising the activities of the LEPC

13. Local Emergency Planning Committee
(LEPC)
13
• Membership must include:
▪ Local police, fire, civil defense,
public health officials, transportation
officials, and environmental
professionals
▪ Representatives of facilities subject
to the emergency planning
requirements
▪ Community groups
▪ The media

14. Tier II
14
History & Importance
What Qualifies?
Reporting

15. Tier II – What Should I Report?
15
• Most substances at or over 10,000 lbs.
• Extremely hazardous substances
▪ EPA List of Lists
• New!
▪ Ammonia (ice rinks)

16. Tier II – List of Lists
16

17. Tier II – Commonly
Overlooked
17
• Fuel oil
• Lead acid batteries
• Oxygen
• Nitrogen
• Road salt and sand

18. Tier II
18
History & Importance
What Qualifies?
Reporting

19. Tier II – Emergency and Hazardous
Chemical Inventory
• Facility name, address,
location
• Emergency contact
• Chemical information
▪ Description
▪ Hazards
▪ Amounts
▪ Locations
• CAS number
• Chemical name
• Descriptors (pure, mixture,
liquid, solid, gas)
• Hazards
▪ Fire
▪ Sudden release of pressure
▪ Reactive
19

20. Physical State & Quantity
20

21. Hazards
21

22. Data Gathered from the SDS
22

23. Physical & Health Hazards
23
Data gathered
from the SDS

24. Storage Locations
24

25. Storage Mixture Components
25

26. Chemicals-in-Inventory: State Fields
26
You must assign a classification to your
record:
- Extremely Hazardous Substance
- Hazardous Chemical (most of us)
- Voluntary report of a chemical on-site

27. Tier II – Emergency and Hazardous
Chemical Inventory, cont.
• Maximum amount (range/pounds)
• Average daily amount
• Number of days on-site
• Storage codes
▪ Aboveground tank
▪ Belowground tank
▪ Tank inside building
▪ Steel drum
▪ Plastic or non-metallic drum
▪ Etc.
• Site plan – locations
• Types of storage
▪ Cylinder
▪ Glass bottles
▪ Tote
▪ Rail car
▪ Etc.
• Storage conditions
▪ Ambient pressure
▪ Ambient temperature
• Confidential information
• Certification
27

28. Agenda
28
Tier II Reporting
Biennial Reporting
OSHA 300 Logs
Q&A

29. Biennial Hazardous Waste Report
29
History & Importance
General Information & Reporting
Generation & Management Forms

30. Resource Conservation and
Recovery Act
2
30
• Creates framework for proper
management of hazardous and
non-hazardous solid waste
• Enacted in 1976 as an
amendment to the Solid Waste
Disposal Act of 1965
• Addressed increasing problems
the nation faced from its growing
volume of municipal and
industrial waste

31. Goals for the Resource Conservation
and Recovery Act
2
31
• Protecting human health and the
natural environment from the
potential hazards of waste disposal
• Energy conservation and natural
resources
• Reducing the amount of waste
generated through source reduction
and recycling
• Ensuring the management of waste
in an environmentally sound manner

32. Biennial Hazardous Waste Report
32
History & Importance
General Information & Reporting
Generation & Management Forms

33. Biennial Hazardous Waste Report
2 3
33
• Large quantity generators (LQG) of hazardous waste
▪ The site generated, in any single calendar month, 1,000 kg (2,200 lbs)
or more of RCRA hazardous waste; or
▪ The site generated, in any single calendar month, or accumulated at
any time, more that 1 kg (2.2 lbs) of RCRA acute hazardous waste; or
▪ The site generated, in any single calendar month, or accumulated at
any time, more than 100 kg (220 lbs) of spill clean-up material
contaminated with RCRA acute hazardous waste
• Very small and small may have to report to state – check with
your state

34. Biennial: General
Information
• Company information
• Reason for submitting
• Information on generation activities
• Regulated waste codes (federal and
state)
• Specifics of waste profiles
▪ Weights
▪ Source codes
▪ Where shipped
34

35. Biennial: How to Submit
• Use EPA Form 8700-13A/B
• Or use the RCRAInfo
website!
35

36. Adding Site to RCRAInfo
• Upon creating a RCRAInfo profile, select “Add Existing Site”
• Enter the site’s EPA ID number or site name and state
• Click search
• Highlight the check-box on the far-right hand side of the search
results for the site you choose and click “Request Access”
• Indicate the permission level you wish to be granted
36

37. Biennial Hazardous Waste Report
37
History & Importance
General Information & Reporting
Generation & Management Forms

38. Generation and Management Forms
38

39. Generation and Management Forms
39

40. Generation and Management Forms
• Hazardous Waste Codes
▪ DXXX – characteristics
▪ FXXX – from non-specific sources
▪ KXXX – waste from specific sources
▪ PXXX – acute hazardous waste from discarded products, residues, etc.
▪ UXXX – toxic wastes from discarded products, residues, etc.
40

41. Generation and Management Forms
• Hazardous Waste Codes
▪ D001 – Ignitable
▪ D022 – Chloroform
▪ D038 – Pyridine
▪ F002 – Assorted spent halogenated solvents
▪ F003 – Assorted spent non-halogenated solvents
▪ F005 – Assorted spent non-halogenated solvents
41

42. Generation and Management Forms
42

43. Generation and Management Forms
• Source code
▪ Description of how the hazardous waste was reported
• Management method code
▪ Type of process system
• Form code
▪ Regarding the physical form or chemical composition of the hazardous
waste reported
43

44. Generation and Management Forms
• Source code
▪ G22 – laboratory analytical wastes (e.g. used chemicals from
laboratory operations)
• Management method code
▪ H141 – the site receiving this waste stores/bulked and transferred the
waste with no reclamation, recovery, destruction, treatment, or disposal
at that site
• Form code
▪ W204 – concentrated halogenated/non-halogenated solvent mixture
44

45. Generation and Management Forms
45

46. Generation and Management Forms
• Waste minimization code
▪ Represents waste minimization, recycling, or pollution prevention
efforts implemented to reduce volume and toxicity of hazardous waste
• Radioactive mixed
▪ Is the waste stream mixed with nuclear sources, special nuclear, or
by-product material
46

47. Generation and Management Forms
• Waste minimization code
▪ N – waste minimization efforts found to be economically or technically
impracticable
• Radioactive mixed
▪ No
47

48. Generation and Management Forms
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49. Generation and Management Forms
• Quantity
▪ Quantity
• Unit of measure (UOM)
▪ Lbs
▪ T
▪ Kg
▪ t
▪ Gal
▪ L
▪ Cy
• Density
▪ Only if UOM is in volume
49

50. Generation and Management Forms
50

51. Generation and Management Forms
• On-site generation and management of hazardous waste
▪ Use of management method code that best identifies the last
substantive purpose/operation performed at your site
• Off-site shipment of hazardous waste
▪ Include the EPA ID of all the locations this waste stream was sent to in
a year
51

52. Biennial Hazardous Waste Report
• All information about waste accumulation can be found on your
Hazardous Waste Manifests
• Triumvirate electronically tracks Hazardous Waste Manifests
52

53. Agenda
53
Tier II Reporting
Biennial Reporting
OSHA 300 Logs
Q&A

54. OSHA 300 Logs
• Conspicuously posted by February 1st
54

55. Who Must Complete the OSHA Injury
and Illness Recordkeeping Forms?
• Many but not all employers
• Exceptions are based on:
▪ Small employer exemption – 10 or fewer employees at all times during
the year
▪ Low-hazard industry exemption – see list of Partially Exempt Industries
(PDF)
55

56. What Cases Need to Be Recorded on
the Forms?
1. Injuries and illnesses
2. Work-related
3. Meet certain severity criteria
56

57. What Is Considered an Injury or
Illness?
• An abnormal condition or disorder
• Not an exposure, unless it results in signs or symptoms
57

58. What Cases Are Work Related?
• Cases caused by events or exposures in the work environment
• Cases contributed to by events or exposures in the work
environment
• Cases significantly aggravated by events or exposures in the
work environment
58

59. What Are the Severity Criteria for
Recording a Work-Related Injury or Illness?
• Death
• Loss of consciousness
• Days away from work
• Restricted work activity or job transfer
• Medical treatment beyond first aid
59

60. Other Recording Criteria
• Significant diagnosed injury or illness
• Needlestick and sharps injuries – section 1904.8
• Medical removal – section 1904.9
• Hearing loss – section 1904.10
• Tuberculosis – section 1904.11
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61. 61

62. Agenda
62
Tier II Reporting
Biennial Reporting
OSHA 300 Logs
Q&A

63. Questions?

64. THANK YOU!
Request Help with Your
Reporting Deadlines:
https://www.triumvirate.com/contact-us-march-2020-reporting-deadlines
Jarred Melvin: jmelvin@triumvirate.com