All4 Inc.

Hydrogen Sulfide Accounting and Reporting in Advance of this Year's Toxic Release Inventory Reports

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Courtesy of All4 Inc.

As environmental personnel gear up for the suite of annual reports due each year, 2013 brings an important change to the Toxic Release Inventory (TRI) report. Beginning with the TRI report due July 1, 2013, releases of hydrogen sulfide (H2S), a colorless, flammable, gas with a characteristic “rotten egg” smell, must be reported.

On October 17, 2011, the U.S. Environmental Protection Agency (U.S. EPA) lifted an Administrative Stay of the Emergency Planning and Community Right-to-Know Act (EPCRA) section 313 TRI reporting requirements for H2S [Chemical Abstracts Service Number (CAS No.) 7783–06–4][1]. As detailed in this Federal Register notice, H2S was added to the EPCRA section 313 list of toxic chemicals in a final rule published in the Federal Register on December 1, 1993. However, on August 22, 1994, U.S. EPA issued an Administrative Stay of the reporting requirements for H2S in order to evaluate issues brought to the Agency’s attention after promulgation of the final rule concerning the human health effect basis for the listing and the Agency’s use of exposure analysis in EPCRA section 313 listing decisions. Although the final rule listing H2S under section 313 of EPCRA remained in force, the stay deferred the reporting requirements for H2S while U.S. EPA completed its further evaluation. U.S. EPA has now completed its further evaluation of additional information that has become available since the stay was put in place regarding the human health and environmental effects of H2S, and the Agency published a position that the stay should be lifted in the February 26, 2010 Federal Register document entitled ‘‘Intent to Consider Lifting Administrative Stay; Opportunity for Public Comment.’’ The October 17, 2011 action that lifted the Administrative Stay established that the first TRI reports to include H2S will be due on July 1, 2013 for reporting year 2012 TRI reports.

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