TRI
Effective October 17, 2011, the administrative stay for reporting hydrogen sulfide is lifted. It will be first reported for RY 2012; due date July 1, 2013. Facilities need to keep records during RY 2012, so they can file their reports for that FY (threshold calculations and Form R/A submissions). For details, go to http://www.gpo.gov/fdsys/pkg/FR-2011-10-17/pdf/2011-23534.pdf#page=1.

On November 26, 2010, EPA finalized a rule to provide communities with additional information about toxic chemicals being released to the environment. The rule, which will be effective on November 30, 2010, adds 16 chemicals to the TRI list of reportable chemicals. For details, go to www.epa.gov/tri.

Tier Two
The 2011 Tier Two reports must be submitted between January 1 and March 1, 2012. Reporters can update the information now for submittal in 2012. Go to Michigan's SARA Title III home page and select "SARA Title III Hazardous Chemical Inventory," then click on the button to access Tier II Manager.

On 7/13/2010, EPA published guidance in the Federal Register regarding the Hazardous Chemical Exemption for Solids under SARA Title III section 311(e)(2): "any substance present as a solid in any manufactured item to the extent exposure to the substance does not occur under normal conditions of use." Under EPA's new interpretation, facilities will only have to include and count the amount of fume or dust emitted or released from a manufactured solid that is being modified to determine if the SARA Title III sections 311 and 312 reporting thresholds have been reached. This interpretation applies to metal, bricks, and any other manufactured solid item that undergoes a modification process. It does not apply to lead in batteries.

Release Reporting
On 7/13/2010, EPA published guidance in the Federal Register regarding the phrase "as soon as practicable" associated with providing a written follow-up emergency notice under the emergency release notification requirements. EPA has decided that 30 days should be sufficient to submit the written follow-up notice of the emergency release to the SERC and LEPC.

Resources
The EPA's List of Lists was updated in May 2010. Links on Michigan's SARA Title III site will take you to the newest version.