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COMPLIANCE SECTION
Form R Reporting
Form R Reports are due July 1, 2005 for Reporting Year 2005 (RY 2005). Form R reporting is required by Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA, or Title III of the Superfund Amendments and Reauthorization Act). Reporting is required to provide the public with information on the releases and waste management of EPCRA Section 313 chemicals in their community and to provide EPA with release information for future regulations.
A completed Form R (or Form A) must be submitted for each chemical listed under EPCRA Section 313 that is manufactured, processed, or otherwise used at each covered facility. You need to report if you meet the following requirements:
- Your facility has ten or more full-time employee equivalents (i.e., a total of 20,000 hours or greater); and,
- Your facility has an SIC Code 10, 12, 20-39, 4911, 4931, 4939, 4953, 5169, 5171, and 7389 (there are some exemptions within the codes, please see the Form R guidance for exemptions); and,
- Your facility manufactures (defined to include importing), processes, or otherwise uses any EPCRA Section 313 chemical in quantities greater than the established threshold in the course of the calendar year.
Evaluating the need to report under Form R can be a time-consuming process as it involves evaluating all materials in use at a facility as well as those manufactured through on-site processes (includes coincidental manufacture). There is a good deal of guidance of this evaluation available on US EPA’s website at www.epa.gov/tri.
EPA has developed software, called TRI-ME, which allows for the submission of Form R reports over the internet. This software is available on US EPA’s website. You may also submit the forms on diskette or on paper. You will also have to submit a copy of the form to your state (see the guidance documents for what your state requires). Some states may also require a submission fee. The Form R guidance document can be found at http://www.epa.gov/tri/report/form_r.pdf.
If you have any questions or concerns about Form R reporting, or if you need assistance in completing Form R reports, please contact Emily Rynders or Jessica Jacobs at 513.489.2255 or by e-mail at ear@paynefirm.com or jlj@paynefirm.com, respectively.
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