History

The Toxics Release Inventory (TRI) is a publicly available database that contains information on toxic chemical releases and other waste management activities reported annually by certain covered industry groups as well as federal facilities. This inventory was established under a federal law called the Emergency Planning and Community Right to Know Act of 1986 (EPCRA) and was expanded by the Pollution Prevention Act of 1990. It requires facilities in certain industries which manufacture, process, or use significant amounts of toxic chemicals, to report annually on their releases of these chemicals. The reports contain information about the types and amounts of toxic chemicals that are released each year to the air, water, land, and by underground injection, as well as information on the quantities of toxic chemicals sent to other facilities for further waste management.

Facilities with 10 or more full-time employees that process more than 25,000 pounds in aggregate, or use greater than 10,000 pounds of any one TRI chemical, are required to report releases annually. The US EPA maintains this information in the TRI.

Facilities that meet requirements must report toxic chemical release and waste management information to the Environmental Protection Agency (EPA) and the State by July 1st. The data from the reports is a resource for learning about toxic chemical releases and pollution prevention activities reported by industrial and federal facilities. TRI data supports informed decision-making by communities, government agencies, companies, and others.

Reporting Criteria

Facilities that meet all the criteria below are required to submit an annual TRI report;

• The facility has 10 or more full-time employee equivalents or a total of 20,000 hours or greater; and
• The facility has a covered primary North American Industry Classification System (NAICS) code (there are some NAICS codes that are exempt to reporting, TRI covered industries are listed on the EPA website); and
• The facility manufactures or processes more than 25,000 lbs. or otherwise uses more than 10,000 lbs. of any EPCRA 313 chemical in one year or exceeds established lower thresholds for Persistent, Bioaccumulative or Toxic (PBT) chemicals in one year.

To determine if chemicals at your facility are manufactured, processed or otherwise used, the following definitions should help;

1. Manufacture – to produce a 313 chemical intentionally or coincidentally. Importing a chemical (or ingredient within a chemical) also falls under this category.
2. Process – any incorporative activity or change of form or physical state (e.g., blending, mixing and repackaging).
3. Otherwise used – non-incorporative chemical usages such as cleaning agents and solvents.

Designated EPCRA 313 chemicals and chemical categories are subject to the reporting requirements of TRI. There are approximately 650 chemicals and 30 chemical categories that are subject to this regulation.

TRI reporting requires facilities to use GHS compliant safety data sheets (SDSs) or metal certifications to identify individual constituents of chemical mixtures and/or metal alloys. Each chemical is then summed from all sources to determine if reporting thresholds have been met.  Once a reporting threshold is met for a chemical, the facility is then responsible for disclosing how much of the chemical was “released” from the facility, meaning emitted to the air, recycled, landfilled, washed down the drain, sent to stormwater, or was treated offsite.

Pitfall – Solvent Compounds

Often overlooked areas of the TRI report include the use of cleaning chemicals, degreasers, clean in place (CIP) units and accounting for volatile organic chemicals present in common solvent-based paints that are emitted to the air and are not part of the final product entering commerce. These are some of the processes that constitute the “otherwise use” category and have a more stringent threshold of 10,000 lbs.

Pitfall – Water Treatment Byproducts

Another overlooked area lies within the water treatment process. Specifically, pH balancing of industrial wastewater. When acids are used, particularly nitric acid, there are compounds created during the process of pH balancing that must be accounted for. This category of chemicals is referred to as nitrate compounds. Therefore, a facility could report nitric acid usage but could also have to report the amount of nitrate compounds created during the pH neutralization process.

Pitfall – Metal Fabrication

The metal fabrication industry has a particularly difficult responsibility due to the many different processes that metal alloys (and all the reportable compounds within the alloys) can undergo in the production of a consumer product. Although alloys are not reportable, many of the compounds within them are (including Copper, Manganese, Zinc, Chromium, Molybdenum).  Facilities must account for welding rod use, time spent grinding on rough edges not to mention the weight of metal going through each individual process. Accounting for all releases of metal elements including how much material is sent to landfill or was recycled takes careful consideration and time to retrieve the proper data.

Pitfall – Glycol Ethers

Other opportunities in determining applicability under the TRI report, arises in the general understanding of the glycol ether family of chemicals. There have been many instances where glycol ethers and ethylene glycol are reported as the same compound, which they are not. The TRI outlines very specific glycol ethers that are reportable and has a general ‘compound’ category for materials that are not specifically called out. In these situations, the use of CAS numbers and the understanding of the general chemical categories is paramount to reporting properly and accurately.

Summary

Once the facility’s chemical information has been assessed, all usage and release data is entered into the EPA’s Central Data Exchange allowing the information to be shared, not only with Federal and State regulatory agencies, but also with the general public. For this reason, it is critical that companies carefully evaluate the assessment process and data retrieval for reportable compounds.

Failure to maintain current inventories, accurately monitor waste streams or understand processes and chemicals can lead to inaccurate reporting, leaving the facility vulnerable to regulatory enforcement. Administrative penalties range from $10,000 to $75,000 per violation, or per day per violation if facilities fail to comply with the reporting requirements.

The process can be lengthy and ample time should be taken to prepare, assess, and complete the necessary reports.

Our EPCRA department supports TRI reports for several industries, we recognize that many variations of processes exist and are available as a resource to our client base to answer questions and complete the filings.

In colder weather, the dangers of Carbon monoxide exposure increase as windows and overhead doors remain closed and air circulation becomes stagnant.  Although we are entering the warmer months, we are seeing an increase in OSHA inspections and additional attention being put towards Carbon monoxide. 

Regular and proper maintenance of CO generating equipment goes a long way in greatly reducing CO related injuries and illnesses.  Examples of CO generating equipment include:  propane/fuel operated powered industrial lift trucks, furnaces, gas fired oven, trucks, vehicles, mobile generators and other gas fired equipment.  If your facility has this type of equipment and it is operated indoors then you should be monitoring your CO levels and making sure you work environment maintains safe air quality.

Carbon monoxide, an odorless, colorless, and tasteless toxic gas, can cause illness and even death to those exposed to its fumes.  Carbon monoxide (CO) is created by the incomplete burning of carbon-containing materials such as natural gas, coal, wood, and petroleum. Exposure to CO prevents blood from carrying oxygen to organs, causing both minor health risks (headaches, nausea, rapid breathing, dizziness) and major health concerns (coronary artery damage, neurological complications, brain dysfunction, death). Low levels of CO exposure over long periods of time as well as high levels of exposure over short periods of time can lead to negative health effects.

Occupational Dangers of CO Exposure

Those working in occupations with higher carbon monoxide exposure risks are more likely to experience CO poisoning. Occupations in which employees are regularly exposed to exhaust pipes, gasoline, charcoal, or high levels of auto traffic are among those most at risk to high carbon monoxide exposure. Sources of CO can include generators, space heaters, compressors, power washers, and welding equipment. Employees at warehouses and steel production plants, as well as those working as welders, forklift operators, mechanics, and diesel engine operators are also at risk of high exposure levels. Employees working at higher risk worksites or with high CO risk equipment should follow deliberate safety protocols in order to reduce the harmful effects of carbon monoxide.

Individuals who smoke cigarettes intake higher levels of carbon monoxide than is deemed safe by OSHA and the Centers for Disease Control and Prevention (CDC). The combination of carbon monoxide exposure at home or through cigarette smoking combined with workplace exposures can lead to a diminished quality of life and a higher risk of chronic CO poisoning.

Carbon Monoxide Exposure Prevention

Identification of carbon monoxide poisoning can prove challenging, as its symptoms mimic those related to various conditions. Symptoms may be overlooked or seem to disappear when, in fact, medical attention is necessary. It is important to be aware of worksite exposures and to take proper safety precautions in order to avoid greater levels of risk to CO. Measuring carbon monoxide levels regularly is necessary in workplace environments with greater risks of this harmful gas.

OSHA outlines multiple recommendations to employers for the reduction and prevention of carbon monoxide poisoning at worksites. Review OSHA’s comprehensive guide for best practices to carbon monoxide prevention for a more detailed account on reducing CO exposures.

• Install an effective ventilation system.
• Maintain the good working order of CO-producing equipment and appliances.
• Prohibit the use of gasoline-powered engines or tools in poorly ventilated areas.
• Provide personal carbon monoxide monitors with audible alarms if potential exposure to CO exists.
• Test air regularly in areas where carbon monoxide may be present.
• Test for oxygen sufficiency before entering areas with suspected CO exposure.
• Educate workers about the sources and conditions that may result in CO poisoning, as well as the symptoms of carbon monoxide exposure.

If you suspect that someone has carbon monoxide poisoning, move them to an open area with fresh airflow before calling for emergency medical assistance. Administer oxygen if they are breathing, or CPR if they have stopped breathing. For more information regarding carbon monoxide prevention review the CDC Prevention Guidelines or Standard Occupational Exposure Criteria.

Questions about you or your employee’s risk for CO exposure? U.S. Compliance EHS professionals can help. Contact me at rgaines@uscompliance.com to learn more.

At U.S. Compliance we hold three values close to the heart of our business. When we created “Compliance as a Service” (CaaS) it was a revolutionary model to offer OSHA and EPA compliance consulting services perfectly designed for growing industrial companies. We created the revolutionary CaaS model because it’s good for our clients, thanks to the elite team members who deliver it. U.S. Compliance is the inventor of CaaS and the only firm built to deliver it.

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Saturday, March 2nd is the deadline to electronically report your OSHA Form 300A data for injuries and illnesses reported in the 2018 calendar year. Specified establishments are required to submit this electronic information.

Establishments, not the firm as a whole, with 250 or more employees are no longer required to electronically submit their OSHA Form 300A. Only a small number of establishments are required to electronically submit their Form 300A data electronically to OSHA. If your establishment meets any of the following criteria an electronic submission is NOT required.

• Peak employment in 2018 was 19 or fewer
• Establishment’s industry is on this list
• Peak employment between 20 and 249 employees in 2018 AND establishment’s industry is NOT on this list

All establishments, regardless of size or industry, must post their OSHA Form 300A on site at each workplace (from February 1 through April 30). OSHA Forms 300, 300A, and 301 records must be kept for five years and readily produced for OSHA inspections. You can read the OSHA ruling on electronic submission requirements in its entirety through the Federal Register.

If you are required to submit the OSHA Form 300A, submissions can be made through the Injury Tracking Application. If you need further clarification on whether or not your establishment must electronically submit the OSHA Form 300A review the OSHA FAQs on Reporting or call U.S. Compliance for more information.

Common Causes of Back Pain

Back pain is often identified as an unavoidable ailment, most especially for those working physically demanding jobs. Back pain is commonly caused by:

• Poor lifting techniques
• Bad posture-seated or standing
• Physical overexertion by force
• Extensive amounts of inactivity

Preventing Back Pain at Work

Avoiding the most common causes of back pain will help you remain pain free at work. Preventative practices include simple changes and awareness of your body’s physical capabilities. Follow the guidelines below to reduce your risk of back related injuries and promote healthier choices in your workplace.

Proper Lifting Techniques

Lift with your legs as you tighten your core abdominal muscles. This method allows you to use the strength of larger muscles instead of the ligaments and smaller muscles in your back. Keep heavy objects close to your body. If an object proves too heavy to lift on your own, ask for help or use equipment designed to properly lift heavy items. Limit the time you spend carrying heavy items by taking short breaks.

Upright Posture

Good posture, whether standing or sitting, improves overall back health and maintains spinal alignment. When standing, balance your weight evenly on both feet. Keep your shoulders raised and level; slouching can add pressure and tightness to your back. When sitting, choose a chair that allows you to rest your feet flat on the floor and comfortably supports the curves of your spine.

Modified Exertion

Small tasks, when repeated throughout the day, can cause strain on your body. Slow build up in the body of these repeated movements can lead to chronic back pain if not addressed properly. Alternate physically demanding tasks with less demanding actions, giving your body recovery breaks.

Activate Your Body

Inactivity over long periods of time can lead to tight muscles and achy limbs. Activating your body gives your muscles an opportunity to engage, recover properly, and renew strength. Take a walking break if you work at a desk for long stretches of time. When seated, march your legs in place or move your arms in circles to keep blood circulation flowing.

Taking part in periodic exercise helps improve overall health and wellness, which helps prevent back pain or injury. Walking, swimming, or aerobic exercises strengthen your back muscles and abdominal core. Improving balance with exercises such as yoga or tai chi decreases your risk of falling and injuring your back.

OSHA Safety Guidelines

The OSHA Technical Manual associates back injury with common workplace activities. Employers should observe employee postures and lifting mechanics. Suggestions for evaluating behaviors that can lead to back injuries are outlined and include surveying employees for safety understandings related to workplace incidents of back pain. In the event of a back injury, employers must record the injury on the OSHA Form 300 log and make any necessary safety adjustments to prevent future incidents.