Inventory Reporting Requirements

Public sector employers receive the Right to Know Survey from the NJ Department of Health (NJDOH). It combines the hazardous substances inventory reporting requirements of both NJDEP and NJDOH. 

Anon. Toxic Substances Control Inventory Reporting Requirements FR. 1977, 42, 46576. 

Environmental Protection Agency (EPA), Toxic Substances Control Act (TSCA) Inventory reporting Requirements, Federal Register, 42, 247, Friday December 23, 1977, pages 64572-64596. In particular, see section 710.7 on pages 64579-64580. 

Tier I and Tier II. Title Ill s Section 311/312, Inventory Reporting, requires reporting any substance for which you have an MSDS and have had a minimum of 10,000 pounds at your facility on any given day in the previous calendar year. These reports are intended to furnish information to the community and the local emergency responders and are provided to the state, local, or county Emergency Planning Commission and the local fire department. There is a slight difference in the amount of information provided in the Tier I and Tier II reports most states now require the Tier II report, which is more comprehensive. 

State permits Most states require state permits for facilities that emit listed air pollutants. In some states federal permits and state permits are combined, while in other states facilities are required to have both a state or county (air district) permit and a federal permit. As part of annual emission inventory reporting requirements, many states already require reporting of HAP and VOC because of their state implementation plan (SIP). 

The Toxic Substances Control Act (TSCA) enacted in 1976 requires manufacturers and importers to notify the EPA 90 days before producing a new chemical product. New uses or applications for a chemical that will afford significantly increased human exposure are also reportable under this regulation. Regulations under this act require annual reports on some 250 chemical substances, their production figures, and any possible exposure of individuals to the chemical. Many of the chemicals reported under the TSCA requirements are also reportable under the inventory reporting requirements of SARA Title III. 

All the PMBs are Hsted on the U.S. EPA s Toxic Substances Control Act NonConfidential Chemical Substances Inventory (Table 8). In the early to mid-1980s, pseudocumene, mesitylene, hemimellitene, and trimethylbenzene were coveted by TSCA Section 8(a) Preliminary Assessment Information Rule (PAIR) reporting requirements (22) and by TSCA Section 8(d) for health and safety data (23). Mesitylene is the subject of a test rule subacute oral toxicity and subchtonic oral toxicity in tats were underway in 1994 (24). The Safe Drinking Water Act (SDWA) allows monitoring for pseudocumene and mesitylene at the discretion of the State (25). Of the PMBs, only pseudocumene is subject to SARA Tide III section 313 annual release reporting (26). 

Submission of EPA Form R. the Toxic Chemical Release Inventory Reporting Form, Is required by section 313 of the Emergency Planning and Community RIght-to-Know Act (Title III of the Superfund Amendments and Reauthoiizatlon Act of 1986), Public Law 99-499. The Information contained in Form R constitutes a report, and the submission of a report to the appropriate authorities constitutes reporting. ... 

Community Right to Know reporting (hazardous substances inventories) is required in New Jersey from selected employers. The identification of the employers who must report is based on their standard industrial classification (SIC) code. In the New Jersey Worker and Community Right to Know Act (N.J.S.A. 34 5A-1... 

Calculates and prints Tier I and Tier II inventory reports. Also assists with inventory and chemical storage information required for Toxic Chemical Release Reports. Requires 640K memory and hard disk. 

SARA has four major provisions or seetions emergeney planning, emergeney release notifieation, eommunity right-to-know reporting requirements, and toxie ehemieal release inventory. 

USEPA publishes proposed formats for emergency inventory forms mid reporting requirements in Federal Register [Section 311-312]... 

Emergency planning. Businesses that produce, use, or store hazardous substances must (a) submit material safety data sheets or the equivalent and (b) file annual inventory report forms to the appropriate local emergency planning commission. Those handling extremely hazardous substances are also required to submit a one-time notice to the state emergency response commission. 

EPA. 1987c. Emergency and hazardous chemical inventory forms and community right-to-know reporting requirements. U.S. Environmental Protection Agency. Federal Register 52(199) 38344. 

In fact, chemicals produced in quantities of 25,000 pounds or less per year comprise a negligible proportion of chemical output. Chemicals listed in the TSCA inventory had a combined production of nearly 4.1 trillion pounds in 1980. Chemicals that have production volumes under 100,000 pounds per year contribute only 0.006 percent to the total (12). A 25,000-pound exemption, then, would free an insignificant proportion of chemical production from reporting requirements. 

---