Search

EPA Updates EPCRA Chemical Reporting to Match GHS HazCom

Posted on 7/21/2016 by Roger Marks

When it comes to overlapping chemical requirements, major changes tend to reverberate across many environmental and safety programs.

On June 13, EPA posted a Final Rule to the Federal Register to update manufacturers’ reporting and recordkeeping responsibilities under Sections 311 and 312 of the Emergency Planning and Community Right-to-Know Act (EPCRA). Among other changes, EPA updated the definition of “hazardous chemical” in Section 311(3) of EPCRA to match the definition given by OSHA’s revised HazCom Standard at 29 CFR 1910.1200(c). 

Even “small” GHS changes can have far-reaching effects. For example, OSHA changed the name of the “Material Safety Data Sheet,” or MSDS, to “Safety Data Sheet”, or SDS, when it harmonized its hazards communication requirements with the global Standard. EPCRA, however, still referred to Material Safety Data Sheets and MSDSs when discussing the information chemical manufacturers must submit to EPA. EPA’s June 13 rulemaking updated the language used to match that used in the now-mandatory GHS hazard communication rules at 29 CFR 1910.1200.

Hazardous chemicals regulated by GHS hazcom rules

EPA Issues Correction to EPCRA Chemical Reporting Rules


However, in the same June 13 rule to conform EPCRA chemical reporting requirements with OSHA’s 2012 Hazard Communication rulemaking to adopt global standards, EPA accidentally removed the phrases “serious eye damage or eye irritation” from the definition of “health hazard” at 40 CFR 370.66.

Consequently, on July 21, EPA followed up the rulemaking with a Final Rule to make a critical correction to the Emergency Planning and Community Right-to-Know Act (EPCRA) chemical reporting requirements. Effective immediately, EPA added “serious eye damage or eye irritation” back into the definition of “health hazard.”

EPCRA Reporting Requirements


Under EPCRA, US EPA requires chemical manufacturers and importers to report on their inventories of toxic chemicals and releases of toxic chemicals from their facilities. “Releases” in this context can mean authorized air emissions, water discharges, water treatment and disposal, and/or accidental releases to the environment.

Need help with Toxic Release Inventory (TRI) reporting? See our Tips for Form R Reports here.  

Questions about GHS and EPCRA reporting? Check out How GHS Affects Your EPCRA Responsibilities.

Or get more information about TRI reporting under EPCRA at EPA’s website.

Expand Your Environmental Expertise


To help chemical industry professionals build confidence making decisions that ensure compliance with EPA chemical, air, and water requirements, Lion will present the expert-led Complete Environmental Regulations Workshop in nine more US cities before the end of 2016. If you're responsible for ensuring site compliance with many complex programs—from the Clean Air and Clean Water Acts to TSCA, FIFRA, EPCRA, and more—this workshop will help you identify the requirements that apply to your facility and make decisions that put your environmental team in a position to succeed.

2016 EPA Regulations Workshops:

Sept. 12–13 Dallas
Sept. 15–16 Little Rock
Sept. 19–20 New Orleans
Sept. 22–23 Houston
Oct. 3–4 Las Vegas
Oct. 6–7 Denver
Oct. 27–28 Salt Lake City
Oct. 31–Nov. 1 San Jose
Nov. 3–4 Los Angeles
 
Sign Up Now.

 

Tags: EPA, EPCRA, GHS, hazard communication, new rules

Find a Post

Compliance Archives

Lion - Quotes

We have a very busy work schedule and using Lion enables us to take the course at our own time. It makes it easy for me to schedule my employees' training.

Timothy Mertes

Hazmat Shipping Professional

Lion's online training is more comprehensive, has better slides, and is a superior training experience than what I would get from other trainers.

Robert Brenner

District Environmental Manager

The training was impressive. I am not a fan of online training but this was put together very well. I would recommend Lion to others.

Donnie James

Quality Manager

The instructor created a great learning environment.

Avinash Thummadi

CAD & Environmental Manager

As always, Lion never disappoints

Paul Resley

Environmental Coordinator

I really enjoyed this training. Even after years on both sides of the comprehension coin, I find myself still learning! The quality of the delivery exceeded much of the training I have received in the past.

Neil Ozonur

Safety Officer

This course went above my expectations from the moment I walked in the door. The instructor led us through two days packed with useful compliance information.

Rachel Stewart

Environmental Manager

These are the best commercial course references I have seen (10+ years). Great job!

Ed Grzybowski

EHS & Facility Engineer

No comparison. Lion has the best RCRA training ever!!

Matt Sabine

Environmental Specialist

The instructor clearly enjoys his job and transmits that enthusiasm. He made a dry subject very interesting and fun.

Teresa Arellanes

EHS Manager

Download Our Latest Whitepaper

Decrease spill, release, and injury risk and increase savings with these "source reduction" strategies to prevent unused chemicals from becoming regulated as hazardous waste.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.