HOMECOMPLIANCE ASSISTANCE
REGULATIONS
ADDITIONAL RESOURCES
ASK THE EXPERTS
Ask STERC

Metal Finishing Compliance Checklists

This set of checklists applies to the following topics:

 

Each checklist only covers common requirements.  Additional requirements including federal, state, and local rules may apply to your facility.  Check the applicable regulations to be certain that all requirements are being met.

Compliance Checklist for Metal Finishing Wastewater and Stormwater Discharges

This checklist covers requirements for existing and new metal finishing companies that discharge or plan to discharge industrial wastewater to publicly owned treatment works (POTWs) and/or stormwater.  It does not cover process wastewater discharges to rivers, streams, etc., which require an NPDES permit.

Question

Response

If Yes, then this Regulation Applies

What You Need to Do if the Regulation Applies

Have You Complied with Requirements?

Does your facility discharge industrial wastewaters or stormwater to a sanitary sewer and route to a Publicly Owned Treatment Works (POTW)?

(   ) Yes

(   ) No

Pretreatment Standards 

40 CFR 403

Obtain permit if from your POTW and comply with national pretreatment standards. Notify POTW of all discharges that could "cause problems to the POTW", including slug loadings [40 CFR 403.12(f)]. 

(   ) Yes

(   ) No

(   ) Not Applicable

Does your facility discharge industrial wastewater or stormwater to a POTW and is your facility subject to New Categorical Pretreatment Standards?

(   ) Yes

(   ) No

Reporting Requirements for POTWs and Industrial Users 

40 CFR 403.12(b)(6)

Within 180 days of a new Categorical Pretreatment Standard or an EPA determination of the applicability of a category to an indirect discharger or 90 days prior to commencement of discharge by a new source, dischargers must submit a Baseline Monitoring Report (BMR) to the Control Authority (or POTW).

(   ) Yes

(   ) No

(   ) Not Applicable

Is your facility an industrial user subject to a Categorical Pretreatment Standard?


Electroplating and metal finishing facilities with a process wastewater discharge are subject to either Electroplating (40 CFR 413) or Metal Finishing (40 CFR 433) standards.

(   ) Yes

(   ) No

Reporting Requirements for POTWs and Industrial Users 

40 CFR 403.12(e)

Submit periodic sampling and analysis reports to the Control Authority on continued compliance in June and December of each year, unless your Control Authority requires more frequent submissions.

(   ) Yes

(   ) No

(   ) Not Applicable

Are you a New Source that has commenced discharge to a POTW or has the EPA established a new Categorical Pretreatment Standard?

(   ) Yes

(   ) No

Reporting Requirements for POTWs and Industrial Users 

40 CFR 403.12(d)

Within 90 days of the final compliance date for Categorical Pretreatment Standards or, for New Sources, 90 days following commencement of discharge of wastewater to the POTW, submit to the Control Authority (or POTW) a 90-day compliance report containing current monitoring results of the monitoring information submitted in the Baseline Monitoring Report (BMR).

(   ) Yes

(   ) No

(   ) Not Applicable

Is your facility an industrial user of a POTW and will there be a "substantial change" in the volume or character of pollutants in the discharge?

(   ) Yes

(   ) No

40 CFR 403.12(j)

Promptly notify the POTW in advance of the "substantial change". Only changes expected to occur "on a regular or routine basis over an extended period of time (3 months or more)" need to be reported.

(   ) Yes

(   ) No

(   ) Not Applicable

Does your facility discharge any amount of RCRA "acute" hazardous waste or more than 15 kilograms of any RCRA hazardous waste per calendar month to a POTW?

(   ) Yes

(   ) No

POTW Pretreatment Standards 

40 CFR 403.12(p)

Report in writing to the POTW, EPA and applicable state hazardous waste authorities within 180 days of the initial discharge the following: 

1) name of hazardous waste discharged

2) type of discharge, i.e., continuous or batch

3) EPA hazardous waste ID number.


Additional information is required to be reported by dischargers of over 100 kilograms of hazardous waste per month.  In the case of new regulations identifying additional characteristics of hazardous waste or listing any additional substance as a hazardous waste, provide similar notification within 90 days.

(   ) Yes

(   ) No

(   ) Not Applicable

Does your facility discharge to a POTW and are you aware of violating a Categorical Pretreatment Standard (through upset or bypass)?

(   ) Yes

(   ) No

Pretreatment Standards 

40 CFR 403.12(g)(2) and 40 CFR .16(c)(3)

Report to the POTW within 24 hours of becoming aware of the violation. The initial notification may be oral and must be followed up with a written notification within 5 days.  Repeat the sampling and analysis and submit the results of the repeat analysis to the Control Authority (or POTW) within 30 days after becoming aware of the violation.

(   ) Yes

(   ) No

(   ) Not Applicable

Does your facility discharge to a POTW and do you anticipate that a bypass will occur?

(   ) Yes

(   ) No

Bypass 

40 CFR 403.17(c)(1)

Submit a notice to the Control Authority (or POTW) of an anticipated bypass at least 10 days prior, if possible.

(   ) Yes

(   ) No

(   ) Not Applicable

Does your facility discharge to a POTW and are you aware of an "unanticipated bypass"?

(   ) Yes

(   ) No

Bypass 

40 CFR 403.17(c)(2)

Within 24 hours of becoming aware of an unanticipated bypass that exceeds applicable pretreatment standards, orally report to the Control Authority, and follow-up with a written submission within 5 days.

(   ) Yes

(   ) No

(   ) Not Applicable

Does your facility discharge to a POTW but is not covered by Categorical Pretreatment Standards?

(   ) Yes

(   ) No

Discharge Reports 

40 CFR 403.12(h)

Non-categorical dischargers must submit to the Control Authority (or POTW) a discharge report every six months in a form and on dates specified by the control authority. The reports must include a description of the nature, concentrations, and flow of the pollutants required to be reported and be based on sampling and analysis performed during the reporting period.

(   ) Yes

(   ) No

(   ) Not Applicable

Stormwater

Does your facility discharge, or plan to discharge stormwater associated with industrial activity?

(   ) Yes

(   ) No

Application Requirements for Stormwater Associated with Industrial Activity 

40 CFR 122.26(c)

Either apply for coverage under the Industrial stormwater general permit or submit a "no exposure" certification.  To be covered under the general permit you must prepare and implement a stormwater pollution prevention plan (SWPPP).

(   ) Yes

(   ) No

(   ) Not Applicable

Compliance Checklist for Hazardous Waste as Regulated Under the Resource Conservation and Recovery Act (RCRA)

First Determine Your Generator Status

Before proceeding with the Hazardous Waste Checklist, determine your generator status.  EPA defines three categories of hazardous waste generators based upon the quantity of hazardous waste they generate per month: 

  1. Very small quantity generators (VSQGs), which generate less than 220 lbs. (100 kg) per month.  (Note: not all states recognize the CESQG category.)
  2. Small quantity generators (SQGs), which generate between 220 lbs. (100 kg) and 2,200 (1,000 kg) per month.  
  3. Large quantity generators (LQGs), which generate more than 2,200 lbs. (1,000 kg) per month. 

When determining your generator status, measure all quantities of listed and characteristic hazardous wastes that are: 

  • Accumulated on the property for any period before disposal or recycling. (i.e., you must count any residue removed from tanks, as well as spent cartridge filters.) 
  • Packaged and transported away from your business. 
  • Placed directly in a regulated treatment or disposal unit at your place of business. 

When determining your generator status, DO NOT measure wastes that: 

  • Are specifically exempted from counting. Examples include lead-acid batteries that will be reclaimed, scrap metal that will be recycled, used oil managed under the used oil provisions of 40 CFR 279, and universal wastes (e.g., batteries, pesticides, and thermostats) managed under 40 CFR 273. 
  • Might be left in the bottom of containers that have been thoroughly emptied through conventional means such as pouring or pumping. 
  • Are left as residue in the bottom of tanks storing products if the residue is not removed from the product tank. 
  • Are reclaimed continuously on site without storing prior to reclamation, such as degreasing solvents. 
  • Are managed in an "elementary neutralization unit," a "totally enclosed treatment unit," or a "wastewater treatment unit," without being stored first. 
  • Are discharged directly to publicly owned treatment works (POTWs) without being stored or accumulated first. This discharge to a POTW must comply with the Clean Water Act. POTWs are public utilities, usually owned by the city, county, or state, that treat industrial and domestic sewage for disposal. 
  • Have already been counted once during the calendar month and are treated on site or reclaimed in some manner and used again. 
  • Are regulated under the universal waste rule or have other special requirements. The federal regulations contain special, limited requirements for managing certain commonly generated wastes. These wastes can be managed following the less burdensome requirements listed below instead of the usual hazardous waste requirements. Check with your state agency to determine if your state has similar regulations.

Please note that depending on your business, you might be regulated under different rules at different times. If, for example, you generate less than 220 lbs. (100 kg) of hazardous waste during the month of June, you would be considered a VSQG for June and your June waste would be subject to the hazardous waste management requirements for VSQGs. If, in July, you generate between 220 and 2,200 lbs. (100 kg to 1,000 kg) of hazardous waste, your generator status would change, and you would be considered an SQG for July. Your July waste would then be subject to the management requirements for SQGs. 

Question

Response

If Yes, then this Regulation Applies

What You Need to Do if the Regulation Applies

Have You Complied with Requirements?

General

Are any potentially hazardous wastes generated at your facility?

(   ) Yes

(   ) No

Hazardous Waste Identification.

40 CFR 262.11

Identify each waste generated and determine if the wastes are listed hazardous wastes or if they are hazardous due to their characteristics.  It is recommended that you document your decisions.

(   ) Yes

(   ) No

(   ) Not Applicable

Is your facility a generator of hazardous waste?

(   ) Yes

(   ) No

EPA Identification Number. 

40 CFR 262.12

Within 90 days of becoming a RCRA hazardous waste generator, obtain an EPA identification number and notify EPA and your state environmental agency of the location and description of waste generating activities.  

(   ) Yes

(   ) No

(   ) Not Applicable

Does your facility ship waste off-site for disposal/ recovery?

(   ) Yes

(   ) No

Licensed Hazardous Waste Transporter and TSDF.

40 CFR 260.380.1(5)

40 CFR 260.380.1(7)

Must ship hazardous waste using licensed transporter and waste must be shipped to licensed TSDF.  In some states VSQGs may transport their own waste provided certain conditions are met.

(   ) Yes

(   ) No

(   ) Not Applicable

Waste Shipment/Manifests/Land Disposal Restrictions

Does your facility generate more than 220 lbs. of hazardous waste per month and ship wastes off-site for disposal?

(   ) Yes

(   ) No

Hazardous Waste Manifests. 

40 CFR 262.20 (a)-(d)

For LQGs and SQGs each off-site hazardous waste shipment must be accompanied by a manifest (learn about EPA's e-Manifest).  Manifests must be retained for a minimum of three years.  VSQGs are not required to use the manifest system.  

(   ) Yes

(   ) No

(   ) Not Applicable

Does your facility generate more than 220 lbs. of hazardous waste per month and ship wastes off-site for disposal?

(   ) Yes

(   ) No

Placards.

40 CFR 262.33

Generator or initial transporter must provide/use appropriate DOT placards.

(   ) Yes

(   ) No

(   ) Not Applicable

Does your facility generate more than 220 lbs. of hazardous waste per month and ship wastes off-site for disposal?

(   ) Yes

(   ) No

Hazardous Waste Exception Reporting. 

40 CFR 262.42

LQGs must contact transporter and/or TSDF if a signed copy of the manifest is not received from TSDF within 35 days and submit an exception report if not received in 45 days.  SQGs must send a copy of the original manifest if a signed copy of the manifest is not received from TSDF within 60 days of shipment.

(   ) Yes

(   ) No

(   ) Not Applicable

Does your facility generate more than 2,200 lbs. of hazardous waste per month and ship wastes off-site to a TSDF facility?

(   ) Yes

(   ) No

Hazardous Waste Biennial Reporting. 

40 CFR 262.41

LQGs must submit a biennial hazardous waste generators report to EPA (or state) by March 1 of each even numbered year (e.g., 2024, 2026, 2028).

(   ) Yes

(   ) No

(   ) Not Applicable

Does your facility generate any wastes restricted from land disposal under 40 CFR 268 (Land Disposal Restrictions)?

(   ) Yes

(   ) No

Land Disposal Restrictions. Testing, Tracking and Recordkeeping Requirements for Generators, Treaters and Disposal Facilities. 

40 CFR 268.7(a)

Generators managing a restricted waste that does or does not meet treatment standards must submit a one-time written notice to each treatment or storage facility receiving the waste. A new notification must be sent when there is a change in the waste or facility. 

Submit a one-time notice to the receiving facility if the waste is not prohibited from land disposal because of an extension, exception, or variance.

(   ) Yes

(   ) No

(   ) Not Applicable

Hazardous Waste Storage

Does your facility store hazardous waste on-site?

(   ) Yes

(   ) No

Accumulation Time.

40 CFR 262.34

LQGs may accumulate hazardous waste on-site for 90 days or less.  In some states, F006 waste may be stored for 180 days or 270 days if the waste is to be recycled.  SQGs may accumulate waste on-site for 180 days or less.  SQGs transporting waste greater than 200 miles may accumulate waste for 270 days.

(   ) Yes

(   ) No

(   ) Not Applicable

Are there hazardous waste storage tanks or container storage areas at your facility?

(   ) Yes

(   ) No

Inspections. 

40 CFR 265.195(c)

Inspect hazardous waste container storage areas weekly.  Perform daily inspections of areas subject to spills.  Document inspections of storage areas.  

(   ) Yes

(   ) No

(   ) Not Applicable

Are containers used for hazardous waste storage?

(   ) Yes

(   ) No

Storage Containers.

.

40 CFR 262.34a(1)

40 CFR 262.34a(4)

Containers must: (1) be in good condition, (2) be compatible with the waste; (3) have closed lids; (4) be separated from one another if they contain incompatible wastes, and (5) be separated by adequate aisle space.

(   ) Yes

(   ) No

(   ) Not Applicable

Are containers properly labeled and marked?

(   ) Yes

(   ) No

Storage Containers.

40 CFR 262.34(a)

Containers must be clearly marked with "Hazardous Waste" and the dates of accumulation.

(   ) Yes

(   ) No

(   ) Not Applicable

Has there been a release, greater than one pound, of hazardous waste from a tank to the environment?

(   ) Yes

(   ) No

Notifications, Reports 

40 CFR 265.196(d)

Report to the EPA Region Administrator within 24 hours of detection.

(   ) Yes

(   ) No

(   ) Not Applicable

Hazardous Waste Storage – Satellite Accumulation

Do you accumulate hazardous waste at or near the point of generation?

(   ) Yes

(   ) No

Satellite Accumulation.


40 CFR 262.34 (c)

For satellite accumulation: (1) waste must be stored in containers that are in good condition and are compatible with waste; (2) containers must be kept closed; (3) quantities must not exceed 55 gal.; (4) containers are put into storage within 3 days of filling; (5) container must be marked identifying contents and beginning date of accumulation; (6) stored in satellite are less than one year; and (7) containers must be under the control of operator.

(   ) Yes

(   ) No

(   ) Not Applicable

Preparedness, Prevention and Emergency Procedures

Do you store hazardous waste on-site?

(   ) Yes

(   ) No

Maintenance and Operation of Facility.

 

40 CFR 262.34(a)(4)

Facility must be operated and maintained to minimize the possibility of an emergency.

(   ) Yes

(   ) No

(   ) Not Applicable

Do you store hazardous waste on-site?

(   ) Yes

(   ) No

Required Equipment.

40 CFR 262.34(a)(4)

Facility must have tested and maintained emergency equipment, including: (1) an internal communications or alarm system; (2) telephone (immediately available at the scene of operations) or a hand-held two-way radio, capable of summoning emergency assistance; (3) adequate and proper spill control, decontamination and safety equipment (fire blankets, respirators, SCBA, absorbents, etc.); (4) fire extinguishers; and (5) adequate water supply.

(   ) Yes

(   ) No

(   ) Not Applicable

Do you store hazardous waste on-site?

(   ) Yes

(   ) No

Emergency Contacts.

40 CFR 262.34(d)(5)

Facility must have: (1) emergency coordinator on premises or on call; and (2) posted near phone, the emergency coordinator's name and phone number, telephone number of fire department, and location of fire extinguisher.

(   ) Yes

(   ) No

(   ) Not Applicable

Do you store hazardous waste on-site?

(   ) Yes

(   ) No

Emergency Agencies.

40 CFR 262.34(d)(4)

Facility must have made arrangements with local emergency agencies.

(   ) Yes

(   ) No

(   ) Not Applicable

Do you treat, store or dispose hazardous waste at your facility and has there been a release, fire, or explosion that could threaten human health, or the environment outside the facility?

(   ) Yes

(   ) No

Emergency Procedures. 

40 CFR 265.56

Notify either the government official designated as the on-scene coordinator for the geographic area or the National Response Center (800-424-8802). If evacuation from the local area is advisable, notify appropriate local authorities.

(   ) Yes

(   ) No

(   ) Not Applicable

Contingency Plan

Does your facility generate more than 2,200 lbs. of hazardous waste per month (i.e., LQG)?

(   ) Yes

(   ) No

Contingency Plan

40 CFR 262.34 (a)(4) referencing 40 CFR 265.53

LQGs are required to have a contingency plan on-site containing specified elements.  Also, plan must be submitted to the local emergency response agencies.

(   ) Yes

(   ) No

(   ) Not Applicable

Training

Does your facility generate more than 2,200 lbs. of hazardous waste per month (i.e., LQG)?

(   ) Yes

(   ) No

Training.

40 CFR 265.16

LQGs are required to have training program, including: (1) personnel training plan with specified elements; (2) program director; (3) personnel trained to respond to emergencies and contingency plan; (4) training documentation; (5) records of current facility personnel; and (6) annual review.

(   ) Yes

(   ) No

(   ) Not Applicable

Does your facility generate between 220 and 2,200 lbs. of hazardous waste per month (i.e., SQG)?

(   ) Yes

(   ) No

Training.

40 CFR 262

SQGs are not required to have a training program but must ensure that employees handling hazardous waste are familiar with proper handling and emergency procedures.

(   ) Yes

(   ) No

(   ) Not Applicable


Compliance Checklist for Clean Air Act

Question

Response

If Yes, then this Regulation Applies

What You Need to Do if the Regulation Applies

Have You Complied with Requirements?

Are there regulated substances above specified threshold quantities for the Accidental Release Prevention Program under the Clean Air Act? 

The list of regulated chemicals was published in the Federal Register.

(   ) Yes

(   ) No

Chemical Accidental Release Prevention 

40 CFR 68.30

Develop a Chemical Accidental Release Prevention Program for your facility within 3 years after the material is listed.

(   ) Yes

(   ) No

(   ) Not Applicable

Are you required to have Continuous Emission Monitoring Systems?

(   ) Yes

(   ) No

New Source Performance Standards 

40 CFR 60.7

Maintain operating records, and records of startup, shutdown, and any malfunctioning of the facility's air pollution control equipment. Provide written notification: 

1) within 30 days of date construction or reconstruction is commenced

2) within 60 days of the anticipated initial start date

3) within 15 days of the actual startup date

4) of any physical or operation change to an existing facility that may increase the emission rate of a regulated pollutant within 60 days, or as soon as possible, before the change is commenced

5) within 30 days prior to a continuous emission monitoring performance demonstration

6) 30 days prior to the anticipated date of opacity observations

Submit a report of excess emissions, as defined in applicable portions of the regulations, by the 30th day of the end of each calendar quarter.

(   ) Yes

(   ) No

(   ) Not Applicable

Does your facility fit under an industry category required to meet maximum achievable control technology (MACT)?

Commonly applicable MACTs:

1. National Emission Standards for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks.

2. Halogenated Cleaning Solvents (degreasing) 

(   ) Yes

(   ) No

Hazardous Air Pollutants 

40 CFR 63

Meet specific required reporting, monitoring, and recordkeeping requirements.

(   ) Yes

(   ) No

(   ) Not Applicable

Compliance Checklist for the Comprehensive Environmental Response, Compensation and Liability Act and Emergency Planning and Community Right-To-Know Act

Question

Response

If Yes, then this Regulation Applies

What You Need to Do if the Regulation Applies

Have You Complied with Requirements?

Do you have knowledge of a release of a hazardous substance into the environment in a quantity equal to or exceeding its reportable quantity? 

Hazardous substances and their reportable quantities are listed in 40 CFR 302.4.

(   ) Yes

(   ) No

Notification Requirements 

40 CFR 302.6

Upon having knowledge of a release of a hazardous substance into the environment equal to or exceeding its reportable quantity, immediately notify the National Response Center at (800) 424-8802. Additional reporting and notifications are required for continuous releases under CERCLA (40 CFR 302.8) 

A written notification must be made to the appropriate EPA Regional Office within 30 days of the initial telephone notification.

(   ) Yes

(   ) No

(   ) Not Applicable

Are you an owner/operator of a facility where hazardous substances were stored, treated, or disposed of and the facility has not been issued a permit or interim status under RCRA.

(   ) Yes

(   ) No

CERCLA Section 103(a)

You should have notified EPA by June 9, 1981 of the existence of the facility as well as the amount and type of any hazardous substance found, and any known, suspected, or likely releases of such substances.

(   ) Yes

(   ) No

(   ) Not Applicable

Are there extremely hazardous substances at your facility in amounts equal to or greater than their threshold planning quantities (TPQ)? 

A list of EHSs and their TPQs is located in Appendix A and B of 40 CFR 355.

(   ) Yes

(   ) No

Emergency Planning Notification 

40 CFR 355.30

Within 60 days, notify the state emergency response commission (SERC) that an extremely hazardous substance (EHS) in excess of the TPQ is at the facility. 

Notify the local emergency planning committee (LEPC) of your facility's representative who will participate as the emergency coordinator in the emergency planning process.

Promptly notify the LEPC of any relevant changes at the facility as they occur or are expected to occur.

Provide information the LEPC requests for developing and implementing the emergency plan.

(   ) Yes

(   ) No

(   ) Not Applicable

Has there been a release of a listed hazardous substance in excess of the reportable quantity that results in exposure to persons off site?

(   ) Yes

(   ) No

Emergency Release Notification 

40 CFR 355.40

Immediately notify the SERC and LEPC. Also notify the LEPC of any area and the SERC of any state likely to be affected by the release. Substances subject to the notification include: 

1) CERCLA hazardous substances 

2) a release of a reportable quantity of an EHS 

Reportable quantities are listed in Appendix A and B of 40 CFR 355. As soon as possible after the immediate notification, you must also provide to the SERC and LEPC a written follow-up emergency notice.

(   ) Yes

(   ) No

(   ) Not Applicable

Is there a continuous release of a listed hazardous substance at your facility?

(   ) Yes

(   ) No

Continuous Release 

40 CFR 302.8

The following notifications must be given: 

1) Initial telephone notification to the National Response Center.

2) Initial written notification to the EPA regional office within 30 days of initial telephone notification

3) Follow-up notification within 30 days of the first anniversary date of the initial written notification.  Submit annual re-evaluation within 30 days of the anniversary date of the initial written notification, and document (notify appropriate EPA Regional Office only if changes in any information previously submitted).

4) Notification of a change in the composition of source(s) of the release or in the other information submitted in the initial written notification of the release within 30 days.

5) Initial telephone notification of "new" release if there is change in composition or source of release, immediately as there is sufficient basis to assert the "new" release is continuous and stable in quantity and rate.

6) Immediate telephone notification of statistically significant increase in release to NRC, and appropriate SERCs and LEPCs (written follow-up emergency notification under EPCRA also required).

(   ) Yes

(   ) No

(   ) Not Applicable

Are any OSHA hazardous chemicals present at your facility?

(   ) Yes

(   ) No

Community RTK--MSDS Reporting 

40 CFR 370.21

Facilities required to have MSDSs under the OSHA hazard communication standard (HCS) are also required to submit this information. The thresholds for reporting hazardous chemicals are: 

- hazardous chemicals (poses a physical or health hazard) in amounts greater than 10,000 lbs.

- extremely hazardous substances (EHS) present in amounts greater than or equal to 500 lbs or the TPQ, whichever is lower.

Within 3 months, submit copies of the MSDSs or a list of hazardous chemicals to the SERC, LEPC and the local fire department. If MSDSs are submitted, a new MSDS must be submitted to the LEPC within 3 months after the information is available.

(   ) Yes

(   ) No

(   ) Not Applicable

Is your facility required to prepare/have an MSDS under OSHA, 29 CFR 1910.1200?

(   ) Yes

(   ) No

Community RTK--Inventory Reporting 

40 CFR 370.25

Prepare and submit to the SERC, LEPC and local fire department (LFD), an emergency and hazardous chemical inventory form (Tier I or Tier II). The hazardous chemicals that must be listed and the threshold levels are the same as those for which an MSDS is required. Tier I must be submitted annually by March 1. If requested by the SERC, LEPC or LFD, submit a Tier II, which includes more detailed information. You may submit a Tier II instead of a Tier I. SERCs, LEPCs and LFDs usually prefer the Tier II.

(   ) Yes

(   ) No

(   ) Not Applicable

Does your facility have 10 or more full-time employees and use more than 10,000 lbs of any of the 300 listed toxic chemicals (e.g., creosote, pentachlorophenol, CCA)? 

Chemicals are listed in 40 CFR 372.65(a).

(   ) Yes

(   ) No

Toxic Release Inventory (TRI)

40 CFR 372.10; 40 CFR 372.22

Submit annual report to the EPA and state on amounts of more than 300 listed toxic chemicals released into the environment routinely or as a result of an accident. These reports (known as the Form R) are due by July 1 of each year. This regulation applies to facilities that are in SIC Codes 20-39 and manufacture, process or use a toxic chemical more than its threshold reporting quantity during the calendar year.

(   ) Yes

(   ) No

(   ) Not Applicable

 

 

 

The information contained in this site is provided for your review and convenience. It is not intended to provide legal advice with respect to any federal, state, or local regulation.
You should consult with legal counsel and appropriate authorities before interpreting any regulations or undertaking any specific course of action.

Please note that many of the regulatory discussions on STERC refer to federal regulations. In many cases, states or local governments have promulgated relevant rules and standards
that are different and/or more stringent than the federal regulations. Therefore, to assure full compliance, you should investigate and comply with all applicable federal, state and local regulations.