That Must Be Reported

TSCA 8(e) requires the submission of information which reasonably supports the conclusion that [a] substance or mixture presents a substantial risk of injury to health or the environment. The reporting obligation extends to information that does not conclusively demonstrate that a substantial risk exists rather reportable information need merely reasonably support a conclusion of substantial risk. Reporting usually requires judgment calls about whether the information rises to a reportable level. Although the ERA discourages over reporting and file dumps, it is prudent to report in cases of uncertainty because of the consequences that follow from a failure to report. 

Many companies will try to use the Agency guidance as providing a bright line as to information that must be reported under TSCA 8(e), although there are no bright line standards to apply across the board. This is particularly so with regard to toxicity data. 

Preliminary data must be reported, and the time to report starts to run as soon as a person capable of appreciating the significance of the information receives it. There is no flexibility to wait imtil the final study is fully completed and reviewed. For example, evidence of reportable increases in benign tumors is often foimd in interim sacrifices during long term studies, and these increases are reportable before the long term study is finalized. 

Letter from Victor Kiinin, Deputy Assistant Administrator, Office of Prevention, Pesticides, and Toxic Substances, EPA, to Robert M. Sussman, 2 (April 2, 1992) [hereinafter Kimm Letter]. 

In general, whether information is reportable under TSCA 8(e) depends upon the seriousness of the adverse effect, and the fact or probability of the effect s occurrence, which is directly related to the fact or probability of exposure. As explained by EPA  

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Symptoms of ergotism that must be reported immediately in dude coolness , numbness and tingling of extremities dyspnea, nausea, confusion, tachycardia or bradycardia, chest pain, hallucinations and convulsions If these reactions occur, the nurse immediately reportsthem to the primary health care provider because use of the drug must be discontinued. 

Written follow-up reports are often a requirement. The HMTA has identified six specific hazardous material incidents that must be reported immediately and again in writing. The RCRA gives managers 15 days after a hazardous waste emergency to submit a written report to the EPA. 

A final dimension of a metric is the intended audience. Information may be disseminated to internal audiences such as employees, supervisors, facility management, senior executives, and the board of directors or to external audiences such as a trade association, regulatory agency, or the general public. Any metric that must be reported for regulatory compliance is, by definition, an external metric. Chapter 6 discusses in greater detail the identification of metrics for various external and internal audiences. 

Reporting procedures vary in different jurisdictions and organizations, such as government or private companies. Minimum spill amounts that must be reported according to federal regulations in Canada and the U.S. vary from 400 to 8000 L, depending on the product spilled. Spill statistics compiled in the past are less reliable than more recent data because few agencies or individuals collected spill statistics before about 1975. 

Limits of Detection. Since the clean-up and recovery achieved in the overall sample workup effects the detection limit of the measurement technique, the actual limit of detection is, relative to the amount of sample available for analysis, always less than the limit of the measurement technique. Thus, if a measurement technique can respond to one microgram of material, but the recovery in the preliminary sample workup is 50%, then the true effective detection limit is two micrograms, and it is this latter value that must be reported. Additionally, the limit of detection of the measurement technique must be taken as not the smallest amount causing a response, but rather the smallest amount to which the analytical criteria employed for qualitative identification can be applied. 

Total suspended solids, pH, temperature, flow, and oils and grease are typical measures that must be reported. In the case of a secondary sewage treatment, the minimum stemdmds for BODj, suspended solids, and pH over a 30-day averaging period are 30 mg/L, 30 mg/L, and 6-9 pH, respectively. In practice, these limits wUl be more stringent, and in many cases there will be separate conditions for summer and winter conditions as well as case-by-case limitations. 

Substantial risk information that must be reported to EPA must be submitted immediately, a term that has no statutory definition in TSCA. In its 2003 Reporting Guidance, EPA stated that a person has immediately informed the Administrator if human health information is received by the EPA not later than the thirtieth calendar day after the date the person obtained such information. The EPA has said it is not sufficient for the submittal to be postmarked within thirty days, and it is up to the submitter to ensure that the EPA receives it within the required time frame. Emergency incidents of environmental contamination must be reported to the EPA by telephone as soon as the person has knowledge of the incident. That could be on the order of minutes or hours, but it would be difficult to argue that waiting a full day is contemplated. If the information is required to be, and has been, reported under another statute administered by EPA, such as CERCEA, the TSCA 8(e) report is unnecessary. Any supplementary information must also be reported immediately. 

It is common in mass spectrometry to assume that the mass of a cation is the same as that of its parent atom, (a) Using data in Table 2.1, determine the number of significant figures that must be reported before the difference in mass of H and H" " is significant, (b) What percentage of the mass of an H atom does the electron represent ... 

An environmental incident (air, water, land) that must be reported to a governmental authority... 

Injuries and illness conditions that must be reported are ... 

Regulation 3 defines those injuries and illnesses arising out of work that must be reported forthwith. 

Employees also will see this as management involvement and interest in their concerns. Overall, morale can increase— not decrease—after an accident if it is handled in a professional manner. Every company will define the kinds of accident events that must be reported. Of course, local and federal laws will also determine what is reportable. 

The reason is not known, but it is an experimental result that must be reported. Finally, Fig. 12.25 [27] presents the FCGR, da/dN, measured on aluminum alloy, type 6061-T6, specimens welded by modified indirect electric arc (MEA). The tensile properties of the base material, HAZ and weld metal are shown in Fig. 12.25 [27]. It can be seen how the strength properties of the HAZ are poor compared to that of the weld metal and, in particular, of the base material. Nevertheless, the higher FCGR, da/dN, is that of the weld metal followed by the HAZ and base material. The FCGR, da/dN, obeys to a Paris law relationship Fig. 12.26... 

When reporting NMR results in scientific publications, the different parameters, equipment characteristics and methods used need to be specified. Table 7.2 summarises the information that must be reported in the method section of scientific publications. 

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