Paint Manufacturer: EPCRA Compliance

GeoInsight assisted a paint manufacturer with their Tier II reporting and TRI annual reports. This includes reporting materials such as fuel oil, salt/sand piles, hydrogen peroxide, ammonia used for refrigeration, and sulfuric acid in batteries. In the case of this paint manufacturer, the chemicals included those with significant fire and toxicity hazards.

 

Facilities that store more than 10,000 pounds of a hazardous chemical (as defined by Occupational, Safety and Health Administration (OSHA) in 29 CFR 1910.1200) or 500 lbs or more (or in excess of its Threshold Planning Quantity) of an extremely hazardous substance (as defined by United States Environmental Protection Agency) during the calendar year, need to file a Tier I or Tier II report by March 1 of the following year. This includes reporting materials such as fuel oil, salt/sand piles, hydrogen peroxide, ammonia used for refrigeration, and sulfuric acid in batteries. In the case of manufacturer, the chemicals included those with significant fire and toxicity hazards.

 

Data Review For Threshold Exceedences

GeoInsight compiled and reviewed inventory data summarizing chemicals stored above the threshold reporting quantity. This also included reviewing the materials safety data sheets (MSDS) to identify if there were new EHS chemicals to report. Tier II reports for the materials that exceed the threshold quantity during the previous calendar year were filed using the Tier II submit software provided by the USEPA. Based on review of previous Tier II reports which had been generated by facility personnel, GeoInsight uncovered gaps in the reports which had not included all of the chemicals which has exceeded reporting thresholds. GeoInsight worked directly with the facility and Region I EPA in helping the facility to self disclose the non-compliance and to correct the previous reports and ensure accuracy of the current reports. After recieving information regarding the EPA's self discovery and self disclosure program, the facility was able to come into full compliance without fines or penalties. The final Tier II reports were submitted to the local emergency planning commission, state emergency planning commission, and local fire department.

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Relevant Tags

  • Compliance
  • EPCRA
  • Manufacturing