On Friday, Dec. 13, 2024, the Environmental Protection Agency (EPA) issued a Federal Register notice announcing availability of a proposed draft 2026 Multi-Sector General Permit for Industrial Stormwater Discharges (MSGP). EPA is requesting comment on its proposed draft 2026 MSGP on or before Feb. 11, 2025. Like the current 2021 MSGP, the 2026 MSGP would apply…
Toxic Chemical Release Reporting — also known as Toxic Release Inventory (TRI) Reporting — is part of the Emergency Planning and Community Right-to-Know Act (EPCRA) regulations at 40 CFR Part 372. TRI Reporting does not apply to recycled materials facilities operating fully under SIC/NAICS Codes 5093/423930 (Recyclable Material Merchant Wholesalers) and/or 5015/423140 (Motor Vehicle Parts…
Chemical Data Reporting (CDR) is a regulation under the Toxic Substances Control Act (TSCA) (see 40 CFR § 711) that requires “manufacturers” of “chemicals” to report certain information to the U.S. Environmental Protection Agency (EPA) every four years. Under TSCA, “manufacturing” includes “importing”, and “chemicals” includes a very wide range of materials including metals (polymers…
Under a rule effective last year (see rule here), certain manufacturers and processors of asbestos are required to report certain information to the Environmental Protection Agency (EPA) on a one-time basis from Feb. 24, 2024 to May 24, 2024. It is possible that a recycler may be required to report because of importing activity during…
On April 3, 2024, the Environmental Protection Agency (EPA) issued an advance notice of proposed rulemaking (ANPRM) titled “Lead Wheel Weights; Regulatory Investigation Under the Toxic Substances Control Act (TSCA)” (see here). Comments are due by May 3, 2024. This ANPRM follows roughly 15 years after EPA had issued a notice requesting public comment on…
On Feb. 29, 2024, the Environmental Protection Agency (EPA) extended the comment deadline on its proposal, “Definition of Hazardous Waste Applicable to Corrective Action for Releases from Solid Waste Management Units,” by 15 days to March 26, 2024. ISRI requests input from members on this proposal by March 19, 2024. EPA seeks to amend and…
Annual Tier II (or Tier 2) Reporting for Calendar Year 2023 under the federal Emergency Planning and Community Right-to-Know Act (EPCRA) regulations at 40 CFR Part 370 has a deadline of March 1, 2024. Tier II reporting is required if your facility is required by OSHA’s Hazard Communication Standard (HCS) to prepare or have a…
On Feb. 8, 2024, the Environmental Protection Agency (EPA) issued two long-awaited connected proposals under Subtitle C of the Resource Conservation and Recovery Act (RCRA) related to per-and polyfluoroalkyl substances (PFAS) and the definition of hazardous waste. Under the proposal titled “Listing of Specific PFAS as Hazardous Constituents,” EPA seeks to add nine specific PFAS…
Whether by design or accident, three different EPA rules for reporting and recordkeeping under Section 8(a) of the Toxic Substances Control Act (TSCA) have reporting periods during some part of 2024. These three TSCA Section 8(a) rules are Asbestos Reporting and Recordkeeping, Chemical Data Reporting (CDR), and PFAS Reporting and Recordkeeping. The Asbestos and PFAS…
By way of a Federal Register notice and follow-up deadline extension, the Environmental Protection Agency (EPA) has requested public input on potential regulatory and non-regulatory approaches to “ensure the proper management of used industrial containers that held hazardous chemicals or hazardous waste.” This request is not a rulemaking proposal, but does seek input by Nov….