If your organization uses chemicals on the jobsite, there’s a good chance your EH&S personnel have spent a great deal of time crafting environmental reports. With ongoing compliance obligations to often-changing regulations and the public pushing for more accountability on a corporate level, it’s important to be as transparent as possible about the hazardous chemicals that your organization handles.
What You’ll Need to Report
When performing an environmental report, organizations are usually required to fill out numerous forms in order to disclose information regarding any hazardous chemicals present at your facility.
Here is a short list of forms and regulations, along with their purposes:
- Tier II – This form came into effect with the Emergency Planning And Community Right-To-Know Act of 1986. According to the Environmental Protection Agency (EPA), the primary purpose of the form is to inform the government and the public of the contents and location of an organization’s inventory of hazardous chemicals. While Tier II is a federal form, state governments often have specific processes that must be followed when submitting the paperwork, so be sure to keep up to date on which requirements you’re obligated to meet.
- Form R – Per the EPA, one Form R must be completed for each chemical used by your organization that is covered by the Toxics Release Inventory (TRI) Program. These chemicals – of which there are currently close to 600 spread across 31 categories – are listed based on their ability to cause either notably negative effects on human health or adverse effects on the natural environment.
- CFATS (DHS) - The Chemical Facility Anti-Terrorism Standard (CFATS) was established by the Department of Homeland Security (DHS) to identify and regulate facilities that manufacturer, use, store or distribute chemicals that pose a high risk to the public in the case of a terrorist attack. For facilities that do not report a chemical of interest (COI) that appears and exceeds a stated quantitative threshold on Appendix A stipulated by the DHS within 60 days, Congress has the ability to fine them up to $25,000 per day and/or can close the site.
- State-Specific Regulations – Each state crafts its own set of guidelines concerning environmental reporting and toxic chemicals, so it’s crucial that you’re aware of which rules affect you. Some of these forms and regulations include the New Jersey RTK Hazardous Substance List, California’s Proposition 65 list, New York City’s List of Hazardous Substances and Michigan’s requirement for a PIPP (pollution incident prevention plan).
The Importance of Environmental Reporting
The process of environmental reporting can be long and arduous – particularly for those organizations that specialize in dealing with chemicals. Yet there are a host of advantages to environmental reporting, including the availability of information afforded to the organization’s stakeholders. In-depth environmental reports not only allow organizations to assure the general public that they’re adhering to applicable laws and regulations, but such reports also give companies a platform to address specific questions and concerns that stakeholders could pose.
Additionally, detailed environmental reporting can be a crucial part of an organization’s steps toward fulfilling corporate social responsibility by proving that hazards are being accounted for and taken care of, which in turn may improve the organization’s legitimacy and public perceptions.