Techno Bits/Technical Bulletins

The United States Environmental Protection Agency, effective January 2000, changed the reporting requirements for certain Persistent Bioaccumulative Toxic (PBT) chemicals under Section 313 of the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA). This action added seven chemicals and two chemical compounds to the list of toxic chemicals subject to reporting under Section 313 and lowered the reporting thresholds for 18 chemicals and chemical categories that meet the EPCRA Section 313 criteria for PBT chemicals. This action reduced the reporting threshold to 100 or 10 pounds, or in the case of dioxins, 0.1 grams. Further, the EPA eliminated the de minimis exemption for the PBT chemicals.

The above changes likely will require many facilities to report PBT chemical activities, which prior to calendar year 2000, were not reportable. Facilities will need to complete a thorough review of chemical and related activities (such as combustion) to determine if PBT chemicals are present. Due to the elimination of the de minimis exemption, chemical users may not rely solely on Material Safety Data Sheet data for this review in order to identify impurities in incoming chemicals. Facilities that conduct chemical reactions, including combustion, need to review if PBT chemicals are formed as the result of undesired chemical byproducts or side reactions. For example, facilities that combust fuel oil, coal, wood or waste-derived fuel, may exceed reporting thresholds for PBT chemicals. Facilities that exceed the PBT chemical reporting thresholds are required to report activities for the applicable chemical on the SARA Form R report, and if located in Massachusetts, the TURA Form S report.

Archived - June 18, 2003