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TRI Reporting heats up for the concrete industry!


By: Doug Ruhlin

Did you see the recent news bulletin from the USEPA about a concrete producer who was fined a considerable amount for failing to conduct required Toxic Release Inventory, also known as TRI Reporting, of the processing of toxic chemicals at their concrete plant?

The Washington state concrete and asphalt producer failed to do their required TRI Reporting for the processing of certain listed toxic chemicals - chiefly lead in cement - to the Federal USEPA and state and local emergency planning agencies.

This clearly indicates the USEPA's intent to vigorously enforce TRI Form R Reporting requirements, including substantial fines when they feel it is justified.

If you are a concrete producer - anyone using cement really - and you haven't been evaluating your applicability for TRI Reporting your lead content in your cement, slag cement, and fly ash used, now is the time! The USEPA has clearly drawn a line in the sand that says you need to report lead in your cement, regardless of whether it's listed on the cement MSDS or not. At this point, industry common knowledge points to the likely presence of lead (and mercury?) in the cement used at the plant, and in all likelihood to the need to be conducting TRI Form R Reporting under Toxic Release Inventory requirements.

Not sure what this is all about? Briefly:

  • SARA Title III Section 313 regulations require that you report the processing or manufacture of over 25,000 pounds of certain listed toxic chemicals (or 10,000 pounds for the less common "otherwise used"), or much lower reporting thresholds in the case of "PBT" (persistent bioaccumulative toxic) chemicals such as lead (which has a 100 pound threshold) or mercury (10 pound threshold).
  • TRI Reporting is NOT the same as Tier II reporting for hazardous materials over a 10,000 pound threshold. Different chemicals, different thresholds, different requirements, different deadlines. Not the same!

Typically, at a concrete plant, the chemicals of main interest are nitrates in certain types of admixtures (must exceed 25,000 pounds) and lead in cements and SCMs (100 pounds). Depending on production and level in cements, it may be possible to trigger the need for mercury reporting also.

What if you don't do this TRI Reporting? Expect strong enforcement action - soon! The USEPA is serious about TRI Reporting, and doesn't look favorably upon those who haven't been doing their required reporting.

Also, if you think you may have been required to do TRI Form R Reporting in the past, but haven't been - be careful! You are on dangerous ground. You may wish to consider the USEPA Audit Policy, and we can help with that.

Regardless of where you stood in the past, it is absolutely critical for you to find out where you are today with regards to TRI Form R Reporting of nitrates and lead in cement. If you need immediate help - contact RMA and let us know.

This is not something to be ignored. TRI Form R Reporting is no joke, and enforcement is becoming a serious manner. Get in compliance, or risk becoming the next USEPA news release!


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