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California Proposition 65 Support

California Proposition 65 applies to businesses which operate plants in California, or otherwise distribute and sell products in California. Trinity Consultants offers extensive related consulting support and expertise, including: Compliance audits and reviews Regulatory applicability and exemptions Proposition 65 Notifications Chemical reviews and exposure assessments Human Health Risk Assessments Safe Harbor Determinations 60-Day Notice of Violations (NOVs) Litigation Support What is Proposition 65? In 1986, California voters passed Proposition 65, the Safe Drinking Water and Toxic Enforcement Act (”Prop 65”). Prop 65 prohibits California businesses from knowingly discharging significant amounts of listed chemicals into sources of drinking water and requires businesses to provide warnings to Californians about significant exposures to chemicals that cause cancer, birth defects, or other reproductive harm. These chemicals may be in the products that Californians purchase, in homes or workplaces, or otherwise released into the environment. Per applicable requirements, the Office of Environmental Health Hazard Assessment (OEHHA) publishes a list of chemicals known to cause cancer, birth defects, or other reproductive harm (the Prop 65 List), including Safe Harbor levels below which notifications are exempted.  Who must comply with Prop 65? Proposition 65 applies to nearly any company that does business in California including industrial facilities, manufacturing, retail, restaurants, hotels, distributors, agriculture, amusement parks, and others. Since it was first published in 1987, the Prop 65 List has grown to include more than 900 chemicals. The list contains a wide range of naturally occurring and synthetic chemicals that include industrial solvents, common household products, food, drugs, dyes and others. Listed chemicals may also include byproducts of chemical processes such as motor vehicle exhaust.   Businesses are required to provide notification to consumers and workers regarding chemical exposures in their products, workplaces, or environmental releases, such as air pollution and water discharges. For more information on Proposition 65, visit the OEHHA website. Trinity Can Help - Contact Us Today In California, Trinity operates four offices with combined resources of more than 75 experienced environmental consultants who service clients throughout the state. These California-focused consultants have decades of permitting, air modeling, and other regulatory compliance experience with local, state and federal requirements, including U.S. Environmental Protection Agency (EPA), Cal/EPA, CUPA agencies, California Air Resources Board (CARB), Department of Toxic Substances Control (DTSC), Office of Environmental Health Hazard Assessment (OEHHA), Regional Water Quality Control Boards, Air Quality Management Districts (AQMD), and others. For assistance in Prop 65 consulting support, call Trinity at +1 (949) 567-9880 or  Contact Us online. Related Articles Potential Chemical Additions to Proposition 65 -- Sep 28, 2016 Clear and Reasonable Warning Revision Impacts on Proposition 65 -- Sep 28, 2016

 

Chemical Facility Anti-Terrorism Standards Compliance

Trinity Consulting Services: CFATS Compliance Support Trinity assists with CFATS compliance, from applicability determination through DHS authorization and compliance inspections, as well as periodic audits. Trinity has valuable experience in each critical step of the CFATS program. Conducting Applicability Determinations Evaluating facility chemicals for CFATS applicabilityPreparing threshold calculations for Chemicals of InterestPreparing non-applicability determinations to document the facility's compliance statusEvaluating alternatives to opt out of the CFATS reporting requirements Performing Top-Screen Analyses (TSA) Preparing a TSA using DHS's Chemical Security Assessment Tool (CSAT)Providing CSAT and Chemical-terrorism Vulnerability Information (CVI) training guidanceEnsuring reporting consistency with other safety and environmental programs (e.g., RMP, PSM, Tier II, Toxic Release Inventory, etc.), including CFATS implications for these other programs Preparing Security Vulnerability Assessments using CSAT Characterizing critical assetsAssessing internal, external, and internally-assisted threatsIdentifying potential security vulnerabilities and existing countermeasuresAssessing risk of an attackAnalyzing countermeasures and evaluating additional measures to lower risk Developing Site Security Plans using CSAT Addressing each vulnerability identified in the SVAEvaluating the 18 risk-based performance standards (as applicable) and developing cost-effective strategies for compliance with these standards Preparing for and assisting with DHS Authorization and Compliance Inspections Maintaining CFATS Compliance Updating existing TSAs, SVAs, and SSPsConducting mock DHS Authorization and Compliance InspectionsPreparing Site Security Plans to assist facilities with managing ongoing SSP requirements (e.g., maintenance, inspection, training, etc.)Preparing custom CFATS trainingConducting CFATS annual compliance audits What is CFATS? The Chemical Facility Anti-Terrorism Standards is a program put in place by the Department of Homeland Security to reduce the security risks associated with possessing specific hazardous chemicals (referred to as Chemicals of Interest). The program focuses on reducing the impact from a potential terrorist attack targeting these COIs by regulating covered chemical facilities. Important Dates 60 Days - Facilities must submit a Top-Screen survey within 60 calendar days of coming into possession of a Chemical of Interest (COI) at or above the Screening Threshold Quantity (STQ). This must be completed with each new possession of a COI or if any material modifications are made to chemicals already submitted. 120 Days (Tier 1-4 Facilities) - Facilities must submit a Security Vulnerability Assessment (SVA) and Site Security Plan (SSP) within 120 calendar days of being notified by DHS that your facility is a high-risk chemical facility (i.e., classified as a Tier 1-4 facility following the Top-Screen submittal). Annually - Facilities within the CFATS program are required to complete an annual compliance audit of the Site Security Plan (SSP) to determine adherence to the site-specific SSP authorized by the Department of Homeland Security and to generate the associated compliance demonstration records. Biennial (Tier 1-2 Facilities) - Facilities must submit an updated Top-Screen survey no sooner than two years, and no more than two years and 60 calendar days, from the date of DHS' approval of the facility's SSP. Triennial (Tier 3-4 Facilities) - Facilities must submit an updated Top-Screen survey no sooner than three years, and no more than three years and 60 calendar days, from the date of DHS' approval of the facility's SSP. Who does CFATS apply to? The CFATS program applies to any chemical facility or individual that possesses or will possess any of the Chemicals of Interest at or above the Screening Threshold Quantity. Every facility or individual must file a Top-Screen survey to report their chemical holdings to the Department of Homeland Security (DHS). DHS then determines which facilities are “high-risk” and must develop a security plan. Regulatory Background Originally implemented in 2007, the Chemical Facility Anti-Terrorism Standards (CFATS) is a Department of Homeland Security regulatory program that addresses security at high-risk chemical facilities. DHS evaluates security risk based on three criteria: Consequence - anticipated result of a successful attack on a facility Vulnerability - likelihood that an attack would be successful Threat - intent and capability of an adversary attacking the facility Trinity Can Help - Contact Us Today Trinity has extensive CFATS experience, including preparing Top-Screen Analyses (TSAs), Security Vulnerability Assessments (SVAs), Site Security Plans (SSPs), and hosting a DHS auditor. For guidance or questions regarding CFATS compliance, please contact Jose Orsini at (407) 982-2891, or Taylor Wilson at (913) 894-4500.

 

Hazard Communication and GHS Services

Trinity Chemical Compliance: Hazard Communication and GHS Services Trinity Consultants is experienced in assisting clients with compliance to global hazard communication regulations. Formerly part of The Redstone Group, our team includes biologists, chemists, industrial hygienists, and toxicologists, including professionals who are qualified by the American Industrial Hygiene Association (AIHA) as Safety Data Sheet Registered Professionals. We have provided hazard communication program support for clients in the U.S. and Canada, Europe, Asia, and Australia and have developed thousands of Safety Data Sheets in over 25 jurisdictions and in 30 languages. Following are some services we provide for Hazard Communication: Program development and auditing Employee training program development and presentation Chemical inventory development Chemical hazard classification according to the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) Preparation of Safety Data Sheets (SDSs) according to local GHS requirements Preparation of Exposure Scenarios and SDS Annex according to EU REACH (Registration, Evaluation, Authorization and potential restriction of Chemical substances) Development of industrial label content according to local GHS requirements Development of consumer label content according to local consumer protection requirements What is the Globally Harmonized System of Classification and Labelling of Chemicals (GHS)? The Globally Harmonized System of Classification and Labelling of Chemicals (GHS) is a standardized system created by the United Nations to communicate the hazards of chemicals through consistent hazard classification and preparation of SDSs and labels. Implementation of the GHS is expected to enhance protection of human health and the environment, provide a hazard communication framework for countries without an existing system, reduce costs by reducing the need for chemical testing, and facilitate international trade for chemicals by having an international system for hazard communication. The GHS has been adopted into law by many countries including the U.S., Canada, Mexico, the EU, Asia, and Australia However, it is important to note that some governments have adopted different versions of the UN GHS, and/or have amended the provisions to include country-specific regulations that were part of their previous hazard communication regulations. Examples include but are not limited to: Hazards Not Otherwise Classified (HNOC) in the U.S. Biological hazards in Canada Specific label requirements in the EU, Brazil and China Important Dates or Timing Compliance dates have already passed for implementing GHS in the countries or regions listed above. Safety Data Sheets and labels must be updated as new information becomes available that impacts chemical hazard classification or the means to protect against or respond to chemical hazards. In Europe, Annex VIII amending Regulation (EC) No 1272/2008 (CLP) has been adopted to standardize information provided to Poison Centres, with compliance dates beginning in 2021. Manufacturers, suppliers, and European importers should begin preparing now to ensure they complete all the notifications by the compliance deadline. Who Needs Hazard Communication Services? All chemical manufacturers, distributors and employers who utilize hazardous chemicals in the workplace are obligated to comply with hazard communication regulations. Trinity Can Help - Contact Us Today! For assistance with Hazard Communication regulations, please contact us at +1 (800) 229-6655 or Contact Us online.

 

PSM/RMP Support

Process Safety Management/Risk Management Program Support Trinity serves a broad cross-section of industries with Process Safety Management (PSM) and Risk Management Program (RMP) support. With the acquisition of PSM specialty firm Provenance Consulting, Trinity provides expertise in all 14 elements of PSM and RMP enabling us to deliver comprehensive and efficient solutions that are custom tailored to a facility's individual need. We understand how the pieces fit together! Trinity Chemical Compliance: PSM/RMP Services Jurisdictional Boundaries - We can determine if your facility is PSM or RMP covered and to what extent the coverage applies. Process Safety Information (PSI)- We implement proven methods to ensure and maintain the accuracy and consistency of PSI. PHA & Risk Assessment - Our team facilitates a variety of Process Hazard Analysis methodologies and other comprehensive risk studies. Mechanical Integrity - We provide full support for implementing and executing a comprehensive and accurate fixed equipment Mechanical Integrity and Inspection program. IPL Lifecycle Support - We assist with any IPL tasks related to documentation, design, and maintenance that are required during the IPL lifecycle, for both new and existing IPLs. Relief System Services - We provide complete relief system lifecycle support including design revalidations and correction, detailed design, installation, flare evaluation, and process simulation. Software Solutions - We deliver custom software applications that can replace or improve your current solutions and help you meet PSM objectives. Custom PSM/RMP Training - We can present standard or customized trainings to your employees to ensure a successful implementation of your PSM/RMP program. Offsite Consequence Analysis (OCA) and Onsite Best Practices Modeling - Trinity's experts develop, update, and review OCA modeling to meet RMP requirements and best practice reviews. These modeling studies can be used to evaluate toxic releases and fire/explosion scenarios, including building damage assessment. Risk Management Plan - We assist clients to prepare and submit Risk Management Plan initial submissions, corrections, and resubmissions via the EPA RMP*eSubmit database. Management of Change (MOC) - We are able to assist you to implement, steward, and audit MOC processes to ensure long-term maintainability and success. Pre-startup Review (PSSR) - We facilitate and support PSSRs including redlining as built PSI, procedures, and ensuring proper completion and documentation. Compliance Audits - Our team provides support in developing and implementing successful compliance audit programs. Incident Investigation - We facilitate investigation methodologies including Root Cause Analysis, Fault-tree, and Five Why. Contractors - We help develop programs that ensure contractors stay informed and have input into PSM/RMP programs. Emergency Response - We develop, prepare, and implement strategies to effectively and safely manage highly hazardous chemical release. We develop Emergency Action or Emergency Response Plans specific to the actions your employees will take in response to releases. Employee Participation - We develop programs that lay the foundation for enhanced employee involvement and input into PSM programs. Hot Work Permit - We develop and audit Hot Work programs to ensure compliance. Trade Secrets- We address trade secret requirements for PSM-covered processes and provide appropriate Confidential Business Information (CBI) protection in Risk Management Plan updates. Important Dates Every 5 Years - Risk Management Plans must be revised and resubmitted to EPAEvery 5 Years - Offsite Consequence Analysis modeling must be reviewed and resubmitted to EPAEvery 5 Years - Process Hazard Analysis must be revalidated or redoneEvery 3 Years - PSM and RMP Compliance Audits must be completedEvery 3 Years - Refresher training must be provided for personnel (Operators and Contractors) involved in operating a processAnnually - Operating procedures must be certified What is PSM? The Process Safety Management of Highly Hazardous Chemicals (29 CFR 1910.119) is a performance based OSHA program developed jointly with industry and is designed to prevent or minimize the consequences of catastrophic releases of highly hazardous chemicals. Facilities that have inventories of flammables (flash point less than 100°F) in excess of 10,000 lbs and/or have chemicals in excess of the quantities of 1910.119 Appendix A are subject to PSM requirements. What is RMP? The Risk Management Program (RMP) Rule was created by EPA to protect the environment and community. Section 112(r) of the Clean Air Act Amendments requires EPA to release regulations and guidance for chemical accident prevention at facilities that use certain hazardous substances. The regulated substances and their respective threshold quantities can be found at 40 CFR 68.130. Trinity Can Help - Contact Us Today For assistance, please contact Natalie VanLiew at (913) 894-4500 x110

 

PSM/RMP Compliance Auditing

Compliance Audit is one of the fourteen required elements of the Process Safety Management (29 CFR 1910.119) and Risk Management Plan (40 CFR 68) Program Level 2 and Program Level 3 programs. The Process Safety Management (PSM) and Risk Management Plan (RMP) programs are intended to be self-governing regulatory programs where facility management personnel monitor internal program performance and audit their PSM and RMP program every three years. The compliance audit is typically conducted by an unbiased third-party but may also be performed in house with appropriate training and expertise. Trinity routinely supports clients in developing and implementing successful compliance audit programs.    The intent of the compliance audit is to internally assess and discover potential gaps in an organization's PSM/RMP program. It reviews PSM/RMP covered operations, documentation, and culture, and compares them against regulatory requirements, recognized and generally accepted good engineering practices (RAGAGEP), and site-specific written procedures. In short, it's a reality check of how well a facility “walks their talk” with respect to their PSM/RMP programs.   PSM/RMP Compliance Audit Scheduling and Recordkeeping   To ensure a facility stays in compliance with the requirements of the PSM/RMP standards, an appropriate audit schedule is developed from the date when the first PSM/RMP covered chemical exceeds its threshold quantity in the system. From this initial date, the facility must conduct a compliance audit within three years and every three years thereafter.    Staff should allow three to six months prior to the three-year milestone to adequately prepare for a compliance audit, to compile necessary process safety and risk management program information, hold audit project planning meetings, complete the audit, and prepare the final report. Completing the site audit two to four weeks prior to the compliance date should provide the facility the necessary time to safely finalize the audit within compliance.   A facility must keep records of the last two compliance audits on site, including a method of tracking the identified action items and their status, completion dates, and responsible party. The site should be able to demonstrate that all previous compliance audit items were addressed appropriately. Carryover action items from one compliance audit to the next could be perceived by OSHA and/or EPA as compliance violations, up to and including willful violations.   PSM/RMP Compliance Audit Preparation   While there is no one “correct” way to prepare for a compliance audit, Trinity's auditors will help ensure you have a well-planned, successful audit. Some facilities develop a “war room” or a LAN location to gather representative PSM/RMP documents and evidence for easy access to the audit team. A kickoff meeting with the auditor and site team is helpful to review the audit agenda and documents requested for review prior to the onsite work. Pre-audit meetings that discuss the audit procedure and schedule with key audit project stakeholders and affected employees will help cultivate PSM/RMP culture and a team-based approach to auditing.    Ideally all affected employees will have at least fundamental PSM/RMP awareness prior to the audit. Trinity Consultants frequently provides associated training for affected employees.    PSM/RMP Compliance Audit Approach   Trinity Consultants utilizes an optimized auditing approach, using recognized and generally accepted practices at its core. Our approach is a simple three step process that includes aligning with facility planning goals, conducting a qualified representative audit, and delivering a final report with reasonable and clear recommendations that put your facility on a path to compliance success.    We provide detailed metrics identifying key focus areas that are statistically significant to improve a facility's overall safety and compliance score. With our audit results, you will understand how to prioritize your time and resources to improve your PSM/RMP program for greatest improvement. For example, a facility may have several findings in mechanical integrity but few in process safety information.  We will address findings in a manner that maximizes resolution with minimal effort.    Trinity's auditors are respected experts in the industry with decades of PSM/RMP knowledge and experience. Our auditors have varied backgrounds and experience including PSM/RMP management, EHS management, operations, maintenance, and plant management in multiple industries such as chemical refining, oil and gas, power generation, and ammonia refrigeration. We understand that a good auditor understands equipment, operations, and people just as much as the regulations.   Trinity's auditors have supported clients on OSHA and EPA surprise inspections and have successfully worked with regulators to reduce violation status, create abatement plans, and implement recommendations from OSHA violation notices and EPA agreed orders. Trinity Consultants' auditors understand what OSHA and EPA look for and we use this valuable perspective to enhance focus and provide relevant results. We are deeply connected to PSM/RMP goals and see every compliance audit as a fresh opportunity to deliver industry best practices and meaningful results to our clients.   After the Audit: PSM/RMP Continuous Improvement   Trinity Consultants' PSM/RMP experts help build fully-compliant programs from scratch, improve existing programs, and optimize mature, successfully implemented PSM programs. We have performed hundreds of PSM and RMP audits and have represented clients successfully through multiple OSHA and EPA inspections through which we have developed an efficient process for continuous improvement of client programs.    When the audit is complete and the final report is in your hands, it is time to start resolving the findings. Using technology, we document the PSM and RMP rules, combine the rules with real-world tasks, and enable management to track and validate PSM compliance performance on a routine basis. When the next compliance audit cycle occurs, our clients are well informed, ready to audit, and typically perform better on compliance audit score results. Contact us to learn about our continuous improvement methodology.   Successful PSM/RMP Compliance Solutions   If your compliance audit is past due or if you're unsure how to address previous compliance audit recommendations, contact Trinity Consultants at (800) 229-6655 or at trinityconsultants.com/ContactUs. We can assist you in developing solutions that avoid or minimize enforcement consequences from lingering audit recommendations. Our compliance auditors will work with you to find an optimal compliance solution and address the potential compliance audit issues.   If your facility is likely to carry over compliance audit recommendations to the next audit, please contact us for assistance. We can often address recommendations utilizing your existing program or by developing a solution for resolution. Carrying over unresolved compliance audit recommendations into the next audit can result in regulatory violations, fines, and a record of non-compliance for the next two audit cycles. A serious compliance situation like this is avoidable; if this situation applies to your facility, please contact us immediately for assistance.  

 

PSM/RMP Mechanical Integrity

What is Mechanical Integrity? OSHA Process Safety Management (29 CFR 1910.119(j)) and EPA Risk Management Program (RMP) Level 3 (40 CFR 68.73) define the Mechanical Integrity (MI) element as a systemized approach utilizing recognized and generally accepted good engineering practices (RAGAGEP), written procedures, and training to manage the on-going maintenance program and integrity of process equipment. EPA's RMP Program Level 2 Maintenance element (40 CFR 68.56) is almost identical in approach to the MI element and requires the facility to have a written maintenance program. EPA's RMP Program Level 1 does not require MI or maintenance programs, but you may want to consider implementing them as best practices relative to OSHA and EPA General Duty clauses.   How to Start Implementing MI Achieving MI compliance begins with an assessment of the facility's equipment and maintenance records. The following equipment is required to be included in the MI program (29 CFR 1910.119(j)(1)(ii), 40 CFR 68.73(a)):   Pressure vessels and storage tanks Piping systems (including piping components such as valves) Relief and vent systems and devices Emergency shutdown systems Controls (including monitoring devices and sensors, alarms, and interlocks) Pumps Trinity can assist in developing an inventory of existing equipment, spare parts, and components for the covered process and utilizing existing resources to streamline this process. We are fluent in computerized maintenance management software systems (CMMS) such as MP2, Maximo, and SAP and can deliver optimized solutions working within the client environment.   Industry faces major MI enforcement and implementation hurdles to demonstrate that site-specific maintenance procedures, testing, and inspections comply with RAGAGEP for their covered process equipment and instrumentation. We facilitate a thorough review of original equipment manufacturer (OEM) manuals; codes such as API, ASME, IEEE, NFPA, and IIAR; and best practices drawn from industry trade groups and Trinity's experience providing MI services nationwide. We develop a site-specific MI program that meets your current requirements and includes a strategy to maximize efficiency for planned “downtime” for the process. Building unique preventive maintenance schedules that coordinate facility production schedules, learned component duty cycles, and OEM requirements poses a challenge that Trinity is well suited to address.  Our goal is to map existing maintenance procedures, work orders, and PM inspections to the MI standard and provide a document that identifies potential gaps and recommends the best path forward for an effective MI program.  Facility management is required to assure its covered processes are built, maintained, inspected, and tested consistent with design specifications, manufacturer's instructions, and RAGAGEP, and that spare parts are managed accordingly. Trinity's approach results in an MI program designed to satisfy these required assurances for maximized safety benefits and successful agency and internal triennial PSM/RMP compliance audits .   MI Support Services   PSM/RMP Covered Process Boundary Determination and Process Equipment Inventory   Understanding the PSM/RMP applicability boundary at your facility is crucial to properly implementing the MI standard. Common questions involve whether utility systems, such as process air or cooling water, fall under the MI standard, and each case should be evaluated against its location and importance to the covered process. Trinity will review your process operations and facility siting study to assist in determining an accurate, realistic approach for PSM/RMP boundaries.  Additionally, MI cannot be properly implemented without a full inventory of what constitutes the “covered process” equipment and instrumentation. Creating this database can be a daunting challenge, for legacy operations and greenfield construction alike. Our consultants are skilled in efficiently gathering field data and inventorying covered process equipment to identify the equipment that must be addressed in the MI program.  Trinity Consultants can provide data gathering and database management solutions for numerous purposes:  Developing a comprehensive equipment and spare parts inventory for the covered process; Gathering and creating a database for technical data and specifications for covered process equipment; Labeling equipment as PSM/RMP MI in CMMS systems such as MP2, Maximo, or SAP; and Determining non-applicable equipment and documenting its basis for exclusion.   OEM and RAGAGEP Standardization   Greenfield construction, existing operations, and legacy covered process systems all require that the facility owners assure the equipment construction and inspection and testing programs comply with manufacturers' recommendations and code requirements, known as RAGAGEP. These OEM manuals, standards, and best practices must be compiled and identified for each piece of equipment in the covered process. An OSHA or EPA auditor may ask the facility maintenance department for specific PMs and the site's documentation demonstrating that those PMs are following RAGAGEP. Auditors will scrutinize the PM frequency, methodology, and tools, parts, and labor used against their expectations, derived from OEM/Code documents, historical MI implementation, field data, previous audits, and agency publications. Trinity Consultants is experienced in navigating the immense database of RAGAGEP information and providing a roadmap for compliance success.   Maintenance Procedures Technical Writing   The PSM/RMP MI standard requires covered processes to have “written procedures” for maintaining the integrity of process equipment. While many facilities have a CMMS implemented with a dedicated PM or work order system in place that defines routine maintenance tasks and activities, we often find that these work orders do not fully address the MI written procedure requirement. For facilities that do not utilize a CMMS for work orders, there is usually an even larger compliance gap for maintenance procedures. Trinity will provide your facility with the following documents that comply with PSM/RMP requirements: Written MI Administrative Program Written MI Inspection and Testing Procedures that follow RAGAGEP Written MI PM procedures for on-going integrity management Trinity Consultants has developed full written MI programs for a wide range of facilities and we have established industry best practices and standards in our approach.    Trinity Can Help Trinity Consultants leverages its combined environmental, safety, and process engineering experience to create comprehensive and well-managed PSM and RMP maintenance solutions. Our nationwide consulting staff has a generous database of best practices, lessons learned, and OSHA/EPA auditing experience to ensure we continuously add value to your process safety systems. Contact Trinity Consultants today at (800) 229-6655 to start the discussion about your process safety maintenance programs.          

 

Toxics Release Inventory (TRI)

What is the Toxics Release Inventory? The Toxics Release Inventory (TRI) is an EPA program that tracks the release and management of specific toxic chemicals that may be a threat to the population and environment. More specifically, chemicals that cause: Cancer or other chronic human health effects Significant adverse acute human health effects Significant adverse environmental effects In an effort to prevent and minimize accidental releases of hazardous substances, EPA developed the Emergency Planning and Community Right-to-Know Act (EPCRA) to support and promote emergency planning, and to provide the public with information about releases, storage, and transfers of toxic chemicals in their community. As a result, U.S. facilities in most industry sectors must report annually how much of each chemical is released to the environment and/or managed through recycling, energy recovery, and treatment. The report is submitted to both the EPA and the state. Important Dates July 1st -Annual Toxic Chemical Release Inventory Report due date Who Must Report and What Must be Reported? Any owner or operator of a facility employing 10 or more full-time employees that manufactures, processes, or otherwise uses one of the 650+ specified chemicals and chemical categories covered by the TRI program above the established level, must report the following data annually: How much of each chemical is released into the environment How much of each chemical is managed through recycling, energy recovery, and treatment The following are TRI-Covered Industry Sectors subject to the TRI reporting program: Manufacturing (NAICS Codes 31-33) Mining (NAICS Code 212) Electric Power Generation (NAICS Code 221) Federal Facilities Hazardous Waste Treatment (NAICS Code 562) Merchant Wholesalers (NAICS Code 424) Wholesale Electronic Markets and Agents Brokers (NAICS Code 425) Publishing (NAICS Codes 511, 512, 519) How Trinity Can Help Trinity assists organizations with annual TRI reporting by: Conducting a chemical-by-chemical threshold determination to confirm reporting applicability Assembling the required information to develop media-by-media release, storage, treatment, and transfer estimates for each chemical considering the variables unique to each site/chemical combination Leveraging custom chemical release tracking and reporting tools consistent with the complexity of the site and the client's budget Auditing previous reports for accuracy and correcting them as needed Providing public and custom TRI training courses Completing EPA's eDisclosure process for reporting past violations Performing risk assessment modeling of the releases Assisting with implementing Pollution Prevention Practices Reviewing the liability from vendors that treat or recycle waste streams Trinity has conducted chemical release estimates for thousands of facilities, some with complex processes involving complicated chemical reactions and dozens of waste streams. We utilize many resources to determine the most appropriate release estimation method for each chemical, including information developed by EPA, industry organizations, and equipment manufacturers. For TRI support, contact Trinity Consultants at (800) 229-6655.

 

Toxic Release Inventory (TRI) Reporting

What is the Toxics Release Inventory? The Toxics Release Inventory (TRI) is an EPA program that tracks the release and management of specific toxic chemicals that may be a threat to the population and environment. More specifically, chemicals that cause: Cancer or other chronic human health effects Significant adverse acute human health effects Significant adverse environmental effects In an effort to prevent and minimize accidental releases of hazardous substances, EPA developed the Emergency Planning and Community Right-to-Know Act (EPCRA) to support and promote emergency planning, and to provide the public with information about releases, storage, and transfers of toxic chemicals in their community. As a result, U.S. facilities in most industry sectors must report annually how much of each chemical is released to the environment and/or managed through recycling, energy recovery, and treatment. The report is submitted to both the EPA and the state. Important Dates July 1st -Annual Toxic Chemical Release Inventory Report due date Who Must Report and What Must be Reported? Any owner or operator of a facility employing 10 or more full-time employees that manufactures, processes, or otherwise uses one of the 650+ specified chemicals and chemical categories covered by the TRI program above the established level, must report the following data annually: How much of each chemical is released into the environment How much of each chemical is managed through recycling, energy recovery, and treatment The following are TRI-Covered Industry Sectors subject to the TRI reporting program: Manufacturing (NAICS Codes 31-33) Mining (NAICS Code 212) Electric Power Generation (NAICS Code 221) Federal Facilities Hazardous Waste Treatment (NAICS Code 562) Merchant Wholesalers (NAICS Code 424) Wholesale Electronic Markets and Agents Brokers (NAICS Code 425) Publishing (NAICS Codes 511, 512, 519) How Trinity Can Help Trinity assists organizations with annual TRI reporting by: Conducting a chemical-by-chemical threshold determination to confirm reporting applicability Assembling the required information to develop media-by-media release, storage, treatment, and transfer estimates for each chemical considering the variables unique to each site/chemical combination Leveraging custom chemical release tracking and reporting tools consistent with the complexity of the site and the client's budget Auditing previous reports for accuracy and correcting them as needed Providing public and custom TRI training courses Completing EPA's eDisclosure process for reporting past violations Performing risk assessment modeling of the releases Assisting with implementing Pollution Prevention Practices Reviewing the liability from vendors that treat or recycle waste streams Trinity has conducted chemical release estimates for thousands of facilities, some with complex processes involving complicated chemical reactions and dozens of waste streams. We utilize many resources to determine the most appropriate release estimation method for each chemical, including information developed by EPA, industry organizations, and equipment manufacturers. For TRI support, contact Trinity Consultants at (800) 229-6655.