From: Joseph Haupt <joseph.haupt**At_Symbol_Here**GMAIL.COM>
Subject: Re: [DCHAS-L] Reportable Quantities?
Date: Mon, 7 Jul 2014 16:45:40 -0400
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: CAFDfkg4e9vHGM+6_q0D37gMS+hN1KfeG47gpkB_3i2Arj7eGyw**At_Symbol_Here**mail.gmail.com
In-Reply-To <4D0A3882C09D2E42BE7C6B7265CB0D5F012306237E**At_Symbol_Here**AVATAR.umhb.edu>


Hello,

Here is the homepage for the EPA TRI reporting:

http://www2.epa.gov/toxics-release-inventory-tri-program

The reporting is required if you meet threshold quantities not necessarily for releasing the substance, but if you "manufacture, process, or otherwise use" it above its respective threshold quantity. The definitions are included in the document linked below. I would also first check the section starting on page 11 to determine if you are required to report to the EPA. Note that the due date is July 1, so you may need to look into getting an extension if necessary. The state of Texas may or may not have additional reporting requirements at the state level - I am not not sure - but I know NJ does have an additional report.

http://www2.epa.gov/sites/production/files/2014-02/documents/rfi_ry2013_120413.pdf

You didn't specify exactly what regulation you are concerned with when it comes to RQ's - there are RQ levels for several regulations including the DOT. However, I assume that you are referring to the SARA 313 regulation. Here is another overview: http://www.msdsonline.com/resources/regulatory-information/sara-reporting.aspx

Joe Haupt
EHS Data Manager
Solvay


On Mon, Jul 7, 2014 at 3:56 PM, Murphy, Dr. Ruth Ann <rmurphy**At_Symbol_Here**umhb.edu> wrote:
Good Afternoon,
Do "Reportable Quantities," RQ's, refer to storage or release?
In other words the RQ for chloroform is listed as 10 pounds and the RQ for silver nitrate as one pound. Is there any requirement that storage of this amount of these chemicals in Texas be reported, and if so, to whom? I can understand reporting release of these chemicals in the stated amounts, but reporting mere storage would require a lot of paperwork.
Thank you.
Ruth Ann
Ruth Ann Murphy, Ph.D.
Professor of Chemistry
Chairperson, Department of Chemistry, Environmental Science and Geology
Co-Chairperson, Health Professions Advisory Committee
Amy LeVesconte Professorship of Chemistry
JAMP Faculty Director
The University of Mary Hardin-Baylor
900 College Street
Belton, TX 76513-2599



On Mon, Jul 7, 2014 at 3:56 PM, Murphy, Dr. Ruth Ann <rmurphy**At_Symbol_Here**umhb.edu> wrote:
Good Afternoon,
Do "Reportable Quantities," RQ's, refer to storage or release?
In other words the RQ for chloroform is listed as 10 pounds and the RQ for silver nitrate as one pound. Is there any requirement that storage of this amount of these chemicals in Texas be reported, and if so, to whom? I can understand reporting release of these chemicals in the stated amounts, but reporting mere storage would require a lot of paperwork.
Thank you.
Ruth Ann
Ruth Ann Murphy, Ph.D.
Professor of Chemistry
Chairperson, Department of Chemistry, Environmental Science and Geology
Co-Chairperson, Health Professions Advisory Committee
Amy LeVesconte Professorship of Chemistry
JAMP Faculty Director
The University of Mary Hardin-Baylor
900 College Street
Belton, TX 76513-2599

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