Updated TSCA Inventory with Unique ID Information
The US Environmental Protection Agency (EPA) has posted the first public Toxic Substances Control Act (TSCA) Inventory to include unique identifier (UID) information. The UID is a numerical identifier assigned to a chemical substance when EPA approves a confidential business information (CBI) claim for specific chemical identity. The agency is required to
- assign a unique identifier to that chemical identity;
- apply this unique identifier to other information or submissions concerning the same substance; and
- ensure that any nonconfidential information received by the agency identifies the chemical substance using the unique identifier, while the specific chemical identity of the chemical substance is protected from disclosure.
This is the first time the public version of the TSCA Inventory includes a field containing a unique identifier for those chemical substances with approved confidentiality claims for specific chemical identity and a field containing the 10-year expiration date from the assertion of such approved claims. The unique identifiers provide the public with a way to connect the specific chemical identity previously listed on the confidential portion of the TSCA Inventory with other relevant information in the agency’s holdings.
OSHA Reporting Requirements
- Employers that haven’t already done so should submit the 2018 Summary of Work-Related Injuries and Illnesses (Form 300A) to Occupational Safety and Health Administration (OSHA). The report is required from
- establishments with 250 or more employees that are required to keep OSHA injury and illness records, and
- establishments with 20 to 249 employees in certain industries.
Learn more at https://www.osha.gov/news/newsreleases/trade/08092019.
Proposal Levels Playing Field for Sources Reducing HAPs
The US EPA has proposed a rule to implement the clear language of the Clean Air Act that allows a “major source” of hazardous air pollutants (HAPs) to reclassify as an “area source,” after acting to limit emissions to below the levels that define major sources. This proposal would relieve reclassified facilities from regulatory requirements intended for much larger emitters and encourage other sources to pursue innovations in pollution reduction technologies, engineering and work practices.
This action would implement EPA’s reading of the Clean Air Act described in a January 2018 guidance memo withdrawing the “once in, always in” policy. Established in 1995, the “once in, always in” policy determined that any facility subject to major source standards always would remain subject to those standards – even if production processes changed or controls were implemented that eliminated or permanently reduced that facility’s potential to emit hazardous air pollutants. States, state organizations and industries frequently noted that the “once in, always in” policy discouraged voluntary pollution abatement and prevention efforts as well as technological innovations that would reduce hazardous air pollution emissions. The EPA’s January 2018 memo found the agency had no authority under the Clean Air Act to limit when a facility may be determined to be an area source and that it may be reclassified as an area source after its potential to emit hazardous air pollutants falls below the levels that define a major source.
OSHA Training Institute
OSHA Training Institute Education Centers offer training courses designed for workers, employers and managers on safety and health hazard recognition and abatement at convenient locations nationwide. Find courses at https://www.osha.gov/otiec/courses/title_description.
Support Sustainability: Become an SGP Community Member
Today’s consumers demand sustainable products that are delivered as part of a sustainable supply chain. Learn about how the Sustainable Green Printing Partnership (SGP) can help businesses invest in a sustainable future and achieve their goals. SGP’s Resources Page has information about its certification program and archived webinars at www.sgppartnership.org/resources. Learn more about getting involved at http://sgppartnership.org/contact-us/.
Doreen M. Monteleone, Ph.D.
Director of Sustainability & EHS Initiatives
RadTech International North America
doreen@radtech.org
News from the West Coast
SCAQMD Sponsors RadLaunch
The South Coast Air Quality Management District (SCAQMD) partnered with RadTech in the RadLaunch program, which connects selected companies to UV/EB industry leaders through funding, guidance and speaking/exhibiting opportunities. The program fits within the mission of the SCAQMD’s Technology Advancement Office, established “to expedite the development, demonstration and commercialization of cleaner technologies and clean-burning fuels.” Technologies that can reduce volatile organic compounds (VOCs) have been identified as a high priority for the SCAQMD. The development of new technologies through the RadLaunch program can help the district achieve its clean air goals. The district has made a $5,000 commitment to the project.
Clean Air Awards Committee Includes RadTech
RadTech has been chosen by the SCAQMD as a member of the Clean Air Awards Nomination Review Committee. The agency presents the awards to honor those who have made outstanding clean air contributions to the health of communities and the economy. In 2005, the RadTech Association received a Clean Air Award for “Excellence in Advancement of Air Pollution Technology.” When RadTech first applied for the award, there was no category that fit the association’s mission of advancing technologies that also achieve environmental benefits. In recognition of RadTech’s contribution to the region, the agency created the award – now called “Innovative Clean Air Technology.”
SCAQMD Considers Test Method for Paints
South Coast Air Quality Management District is working with members of industry, academia and other regulatory agencies to address issues with laboratory volatile organic compound (VOC) test methods. Most regulations rely upon a gravimetric analysis, using either the US Environmental Protection Agency’s (EPA) Method 24 or the SCAQMD Method 304. The agencies have recognized inherent uncertainties to these tests when the VOC content of the material being tested approaches zero. Most industry laboratories have switched to direct gas chromatography (GC) method: either ASTM D6886 or SCAQMD Method 313. RadTech has long opposed using GC methods on UV/EB/LED materials, citing lack of reproducibility and added cost. The “Scope and Application” section of Method 313 specifically states: “This method is not to be used for two-component coatings, Ultraviolet/Electron Beam (UV/EB)-cured coatings or other coatings which require specialized curing conditions.” The current work appears to be focused on low-VOC architectural coatings, most commonly called architectural and industrial maintenance (AIM) coatings. The district formed a working group composed of industry representatives, regulators and California State University at San Luis Obispo to update Method 313 and address the definition of a VOC. A draft of SCAQMD Method 319 – Determination of Exclusion Status for Compounds in Film-Forming Coatings – can be found at http://www.aqmd.gov/docs/default-source/planning/architectural-coatings/current-activities-support-documents/south-coast-aqmd-draft-m3194178a6efc2b66f27bf6fff00004a91a9.pdf?sfvrsn=0.
Source Testing Group Formed
In response to requests from stakeholders for updated default toxic emission factors, including streamlined staff review and approval of source tests used for emissions reporting; the South Coast Air Quality Management District board has directed its staff to assess and improve its source test review/approval process. Source tests are used in permit processing, demonstration of compliance and criteria pollutant, as well as air toxic emissions quantification. The agency receives more than 800 source tests per year. SCAQMD has seen an increase in source testing requirements in recent years. The staff attributes it mostly to:
- requirements for compliance demonstrations
- periodic testing requirements through permit conditions and
- new technology and reformulations that require broader testing for toxic emissions.
In consultation with the Equate Working Group – an advisory committee – the agency plans to set priorities for processing the existing and anticipated inventory of source tests. It is developing a process and schedule to address the expected increase in source test reviews due to a recent increase in fees for toxic materials. Reducing current inventory of source tests, as well as targets for completion of reviews, also will be reviewed. Electronic submissions, tracking/dashboard and routing system are some of the solutions under consideration. A report to the Stationary Source Committee is expected in December 2019.
Rita Loof
Director of Regional Environmental Affairs
RadTech International North America
rita@radtech.org
