FOR IMMEDIATE RELEASE—April 2, 2007—Ypsilanti, MI—The EPA’s 2006 TRI-Made Easy (TRI-ME) is now available for download on the EPA’s web site (http://www.epa.gov/tri/report/software/index.htm). Quantum has downloaded the software and reviewed the list of reportable chemicals to last year’s list. There are no permanent changes to the list; however three chemicals currently on the list are under administrative stay so are not reportable for 2006. These chemicals can remain off the 2006 313 list in FacTS™.
These chemicals are:
- Methyl Mercaptan CAS NO: 74-93-1
- Hydrogen Sulfide CAS NO: 7783-06-4
- 2,2-dibromo-3-nitrilopropionamide CAS NO: 10222-01-2
NAICS Codes
The EPA has switched from using the Standard Industrial Classification (SIC) codes to determine what facilities must complete the SARA 313 reports, to using the North American Industry Classification (NAICS) codes. FacTS™ has been updated to enter the new NAICS code, but can still store/display the old SIC codes for archived records. FacTS™ customers with the Form R modules will be contacted by their FacTS™ project manager to coordinate delivery of the applicable upgrade.
Expanded Form A
In addition, the rules for when a Form A can be used have been expanded for 2006. The Form A is a simpler form with less detailed information, which under certain conditions, can be submitted in lieu of the more detailed Form R. From 1995 through 2005, the rule to determine when a Form A could be used versus a Form R was:
Is the amount manufactured, OR processed, OR otherwise used, less than or equal to 1,000,000 pounds AND non-PBT AND is the reportable amount less than or equal to 500 lbs/yr.
The new rule expands eligibility for TRI reporters to use Form A when:
Reporting facilities are allowed to use Form A for non-PBT (Persistent, Bioaccumulative, and Toxic) chemicals, so long as releases or other disposal is not greater than 2,000 pounds as part of the total waste management limit for the chemical, which is not more than 5,000 pounds.
Form A may be used for certain chemicals of greater concern (i.e., persistent, bioaccumulative, and toxic, or PBT, chemicals) when there are no releases or other disposal and no more than 500 pounds of other waste management (e.g., recycling or treatment).
This rule makes Form A available for use in reporting PBT chemicals under limited circumstances for the first time in the program’s history.
“Non-production related waste,” i.e., waste from one time events such as facility cleanups or extraordinary weather events must be counted when determining eligibility to use Form A.
Since Form As were introduced, FacTS™ customers have required that they chose for themselves when to report a Form A or a Form R. Some have preferred to always submit Form Rs because they feel the greater level of detail better demonstrates their reduction of 313 chemicals. FacTS™ supports both forms but allows each customer to select the type on a chemical-by-chemical basis.
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Since 1986 Quantum Compliance has helped corporations increase productivity and profit, using information technology to comply with EHS regulations. Our software embeds sustainable Environmental, Health, and Safety (EHS) practices into a company’s daily operations. These tools collect and analyze procedural and business systems data to generate practical, easy-to-understand EHS performance reports.
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