even months after an incident occurred that can affect the “days away,” “transfer” and other information on the log.

Tier 2 Reports – Has your company started any new processes this past year?  Are there any new chemicals stored on site?  If so, determine the quantities and how and where the materials are managed on site.  Now is a good time to update your chemical inventory so that you are ready and able to prepare your Tier 2 Report.  Tier 2 Reports are due March 1, 2021.  ​

And, don’t forget, a thorough and accurate chemical inventory supports other programs like Right-to-Know, oil and chemical spill prevention (SPCC and PIPP) and storm water pollution prevention. 
 
Air Permit Reports – Depending on your emission units and permit terms and conditions, you may have monthly, quarterly, semi-annual or annual reports to submit.  It is a good idea to check in with the staff responsible for collecting data to ensure it is complete and accurate and that the data will be available when needed. 
 
Toxic Release Inventory – TRI reports aren’t due until July 1st.  And although you still have some time, it is always a good idea to get a jump start on collecting necessary data, which can be time consuming and cumbersome.  If you already know that chemical quantities exceed thresholds, start ordering 2020 data or reports from appropriate company departments and vendors now so you have plenty of time to assemble and analyze the data to prepare the TRI report and submit it on time. 
 
If you are unsure whether TRI Reporting is required, the first step is to conduct an Applicability Determination to identify whether regulatory thresholds have been exceeded.  This activity examines the raw materials, processes and wastes generated by a facility and compares the results with the regulatory thresholds.  If thresholds are exceeded, then a TRI report Form A or Form R are required. 
 
Online Reporting Access – Just like the fire department wants you to check the batteries in the smoke detectors at home during the New Year, it is also a great time to check your usernames and passwords to make sure they are current and still work so that your online access is not interrupted when you go to enter your data.  Some agencies even require you to change your password annually.  The new year is also a good time to make sure that everyone at the facility involved in the reporting process still knows their login information and how to use it.  Getting these items resolved now will help avoid headaches as you approach reporting deadlines. 
 

By now you should be knee deep in assembling information reviewing data and getting ready to prepare and submit your Q1 reports. 
 
OSHA 300A Logs – Your OSHA Log Posting is due February 1st.  Make sure you have re-reviewed some 2016 incidents with your incident investigation team to ensure you have all the information you need and that it is still current.  Sometimes reporting information changes weeks and even months after an incident so you want to be sure days away, transfer and other information is still correct.
 
Hazardous Waste Biennial Report – Review your waste shipping records to verify you have all the original signed manifests, LDR documents and waste characterization files for all wastes generated during 2016.  Do a quick generator status check to determine whether or not your generator status has changed. 
 
Tier 2 Reports – Has your company started any new processes this past year or started storing new chemicals on site?  If so, determine the quantities you now store and how the materials are managed.  This is a good time to update your chemical inventory. 
 
Air Permit Reports – Depending on your emission units and permit terms and conditions, you may have monthly, quarterly, semi-annual and annual reports to submit.  It is a good idea to check in with the staff responsible for collecting the data to ensure it will be available when needed and it is accurate. 
 
Online Reporting Access – Just like the fire department wants you to check the batteries in the smoke detectors in your home, the new year is a good time to check your online access user names and passwords to make sure they are current and still work.  Some agencies require you to change your password annually.  The new year is a good time to make sure that everyone involved in the reporting process still knows their login information.  Getting these items resolved now will help avoid headaches as you approach reporting deadlines. 
 
If you have questions, give us a call and we will be happy to help.  
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by Bill Schneider

MIOSHA announced that beginning September 1, 2015, the state will implement the new federal injury reporting rules for severe injuries that became effective January 1st of this year.  All Michigan employers will be required to report any work-related amputation, loss of an eye, or in-patient hospitalization of any employee, within 24 hours of the incident.  Twenty-five additional industries have been included in these rules, too.