In the Fall CTI Newsletter, I had developed and shared a 2017 Health and Safety Compliance Calendar with our avid readers, recommending some advanced thinking and planning for the health and safety portion of a 2017 Environmental, Health & Safety (EHS) compliance calendar. Many of you also wear the hat of “environmental compliance manager” or some similar moniker. Hence, I offer each one of you a gift this holiday season – a sample of a simple Environmental Protection Agency (EPA) compliance calendar for a fictional company, “ABC Manufacturing Company”, which is a Large Quantity Generator (LQG) of hazardous waste under the Environmental Protection Agency’s (EPA’s) Resource Conservation and Recovery Act (RCRA). The facility has a paint spray booth vented through the ceiling for which they have an air permit to install and operate. Storing the regulatory threshold of oils at their site, ABC Manufacturing Company also meets the regulatory requirement of developing and maintaining an EPA Spill Prevention Control and Countermeasures (SPCC)(C) Plan, and falls under SARA’s(B) Annual Tier II Facility Emergency and Hazardous Chemical Inventory Report and Toxic Release Inventory (TRI) Report.
As with CTI’s last newsletter, please feel free to take what applies to your facility and give it a try! Please be aware – many of the EPA requirements may require weekly, monthly, or quarterly record-keeping, facility inspections, employee training, or even sampling requirements at times throughout the year (A). These more frequent requirements must be reviewed based on the plans, programs, or permits that are applicable to your facility. Remember, the sample below is meant only to help you envision a calendar for your facility. I would be happy to help you to develop a complete Environmental, Health & Safety compliance calendar based on your company’s specific regulatory requirements!
Merry Christmas, one and all!
| ABC Manufacturing Environmental Compliance Calendar | ||
| Month | EPA Regulation | Notes / Comments |
| 1. January | ||
| 2. February | Air Permit Evaluation Report (PER)
DUE: February 15TH – (Annual) |
NOTE: PER submittal dates may differ per PTIO permit conditions.
For a facility that has been issued a state air Permit-To-Install and Operate (PTIO) – Ohio Administrative Code (OAC) 3745-15-03 |
| 3. March | Tier II Facility Emergency and Hazardous Chemical Inventory Report (aka, SERC – State Emergency Response Commission)
DUE: March 1ST (Annual) |
SARA(E.) 311 / 312 (Tier I / Tier II) Facility Emergency and Hazardous Chemical Inventory Report
All facilities which maintain SDSs for hazardous chemicals at their site(s) must report those chemicals exceeding regulatory thresholds annually. – OAC 3750-30; 40 Code of Federal Regulations (CFR) 370.20-370.45 |
| RCRA Hazardous Waste Biennial Report
DUE: March 1ST , 2018
|
RCRA Hazardous Waste Biennial Report
every even-numbered year – OAC 3745-52-41; 40 CFR 262.41 |
|
| 4. April | ||
| 5. May | ||
| 6. June | DOT Hazardous Materials (Hazmat) Transportation Registration & Fee
DUE: June 30TH, for the 2017-2018 Year |
Federal hazardous material transportation law requires a person who offers for transportation certain hazardous materials, including hazardous wastes, to file a registration statement with the U.S. Department of Transportation and to pay an annual registration fee. – 49 CFR 107.601-107.620 |
| 7. July | SARA(E.) 313 / Toxic Release Inventory (TRI) Report [Form R Report]
DUE: July 1ST (Annual) |
OAC 3745-100; 40 CFR 372 |
| 8. August | ||
| 9. September | RCRA (Hazardous Waste Generator) Personnel Training
DUE: Annually. [No fixed date].
|
OAC 3745-65-16; 40 CFR 262.34; 40 CFR 265.16 from §262.34(a)(4) |
| 10. October | Spill Prevention Control and Countermeasure (SPCC) Plan Personnel Training
DUE: Annually. [No fixed date]. |
Annual personnel training and oil discharge prevention briefings for oil-handling employees. – 40 CFR 112.7, 40 CFR 112.21, and 40 CFR 112 Appendix F |
| 11. November | ||
| 12. December | ||
FOOTNOTES:
- LQGs are required to perform weekly inspections of hazardous waste containers to make sure they are maintained and managed in compliance with the regulations.
- SARA = Superfund Amendments and Reauthorization Act (of 1986)
- SPCC = Spill Prevention Control and Countermeasures (Plan). Please Note:
- Depending on the SPCC Plan, monthly or more frequent inspections of oil-containing tanks and other containers for signs of deterioration, discharges, or accumulations of oil inside diked areas.
- The SPCC Plan must be reviewed once every 5 years from the date the facility becomes subject to the rule.
Compliance Technologies, Inc. has a team of experts ready to develop a customized OSHA & EPA compliance calendar for you now. Call or email us now to start your 2017 Compliance Calendar.
