iJuly 1st is right around the corner. We hope most of you are either done or well on your way to completing your TRI number crunching. While there is still plenty of time to get the TRI reports completed, keep in mind there are some potential pitfalls that can stop you in your tracks:
Due Diligence - TRI Applicability Determination
If you are a small but growing company, don’t ignore the TRI reporting again this year because you have never had to report in the past. Do your annual Due Diligence and prepare some calculations and analysis that you can place in a compliance folder for when MDEQ or USEPA come to visit. This way you can easily demonstrate that your facility in not required to report. Your facility is required to report if it meets ALL three of these threshold criteria:
SRM can help you with your TRI determination. USEPA also has resources to help you at their website.
TRI-Me Web Access
USEPA requires companies to update their passwords. If you are running short on time or the certifying official is going out of town on a long business trip in two days, updating crucial information can pose a problem. What if you need to change the certifying official due to corporate reorganization? Changing information in the TRI-ME system can take a week or two to complete and can be disruptive. So you shouldn’t wait until the last minute to update your information. A good rule of thumb is to get onto the CDX system sooner rather than later and make sure you and your certifying official can access the CDX system and your TRI forms. Update your passwords as necessary.
Check Your Formulas
If you are like many TRI preparers, you use spreadsheets to estimate chemical usage and emissions. As we enter or remove data from year to year we can move linked data cells around the worksheet causing errors in the calculations. In addition, “Fat-Finger Syndrome” is still incurable and people often delete or move links without even knowing it. So, take some time every year to examine your formulas and links between worksheets to ensure data integrity.
Contact SRM if you have questions about TRI applicability or reporting.
Once again SRM is attending and hosting a booth at the semi-annual Michigan Environmental Compliance Conference (MECC) located at the Lansing Center on June 12 and 13, 2018. There will be over 70 educational sessions, 38 exhibitors, and 18 DEQ program exhibitors. Click here for more information.
Come visit SRM at Booth 35. We hope to see you there!!
Beginning July 1, 2018, all hazardous waste shipments from
small and large quantity hazardous waste generators, and all
shipments of polychlorinated biphenyl (PCB) waste, requiring a
uniform manifest, must be submitted to the U.S. EPA for
tracking in the online e-Manifest system.
The receiving TSDF is responsible for submitting the e-Manifest information it receives to the U.S. EPA. It is also responsible for paying any e-Manifest processing fees due to the U.S. EPA following deployment. To ensure a smooth transition, generators are encouraged to review e-Manifest resources shared with them by their TSDF and to review resources on the MDEQ and USEPA websites.
Highlights for Generators
The eManifest online system is located in the USEPA CDX online system under RCRA Info and is currently available to explore. You will need to open a CDX account if you don’t already have one. There is a Youtube video from USEPA that walks you through a fictitious site and may be helpful.
To get more information, check out the MDEQ and USEPA resource pages, or contact SRM for assistance.
The next Hazardous Waste Biennial Report deadline is March 1, 2018 and covers activities during calendar year 2017. The Michigan DEQ will not be sending biennial packets to waste generators. Instead, Large Quantity Generators and TSDFs will be required to report using the federal forms and instructions.
While the MDEQ will accept paper copies, it is encouraging facilities to submit their Biennial Report data electronically through the Biennial Report component of the USEPA RCRAInfo Industry Application (RIA).
The RCRAInfo login page can be used to set up a RCRAInfo account and login. The web site provides guidance and information to be followed to prepare and submit the report. Additional information for submitting Biennial Reports to the MDEQ either electronically or on paper can be found at the MDEQ web site for Biennial Reporting.
Because the USEPA has adopted GHS, the reporting requirements under EPCRA have expanded. The Tier 2 reporting requirements now have 24 physical and health hazard categories. The new Tier 2 form now has 13 physical hazard choices and 11 health hazard choices. The following table lists the new categories:
The MDEQ is asking Michigan facilities to start updating their Tier 2 reports now to avoid the rush in January and February. The MDEQ Tier ll Manager software system is updated and ready to go!
USEPA has released the updated Tier 2 Submit software for CY 2017 for those companies with facilities in other states.
Helpful Hint in preparing 2018 Tier 2 Reports: Be sure to obtain updated SDSs. They will be incredibly helpful in selecting the hazard category for the chemicals you have on site. If you need assistance updating your Tier 2 report for 2017, contact our professionals at SRM.
For more information, check out the following links for the MDEQ and USEPA web sites