At the beginning of a new year, it is important to review facility operations and identify environmental, health and safety (EHS) reporting requirements to ensure reporting deadlines are met. Reporting requirements may have been modified since prior year’s reports, so it is also important to review reporting instructions and regulatory changes before filing.
The following is a brief summary of common, recurring EHS reporting requirements:
- EPCRA Tier II Reporting – This report provides State, local officials and the public with specific information about chemicals stored at a facility and potential hazards associated with those chemicals. This report is due annually by March 1 for any facility that exceeds the reporting thresholds. Follow state procedures for filing these reports.
- OSHA Injury and Illness Reporting – OSHA requires establishments that meet minimum number of employee thresholds in specified industries to file injury and illness information electronically annually by March 2.
- EPA Greenhouse Gas Reporting – This report is required for large greenhouse gas emission sources. The report is due annually by March 31.
- EPCRA Toxic Release Inventory Report – This report is required by certain industrial facilities that manufacture, process, or otherwise use reportable chemicals above the reporting thresholds. The report is due annually by July 1.
- DOT Hazmat Registration – Offerors and transporters of certain quantities and types of hazardous materials, including hazardous wastes, are required to file an annual registration statement with the U.S. Department of Transportation and to pay a fee. This report is due annually by July 1.
- Small Quantity Hazardous Waste Generator (SQG) Site Notification Update – This report is required by SQGs located in a State where EPA is the enforcement authority or where the State enforcement authority has adopted the EPA hazardous waste rule. The report is due every four years, with the first reporting deadline being September 1, 2021.
- Air Emissions Inventories – These reports are triggered by State air regulations and are triggered by air permit requirements and/or the air emissions that occurred at the facility during the reporting period. State regulations and/or air permit requirements specify reporting due dates.
Even if a facility does not trigger the reporting requirement, many of the associated regulations require that documentation is maintained demonstrating a report was not required to be submitted.
This is just a small list of potentially applicable EHS reporting requirements. If you need assistance identifying regulatory reporting requirements or would like to develop an EHS Compliance Calendar specific to your facility EHS regulatory applicability, contact a VBA expert for help.