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Environmental Services

SARA Title III Reporting

Sections 301-312 [aka the Emergency Planning & Community-to-Know Act (EPCRA) &/or Tier II]. Environmental Compliance Reporting encompasses Sections 302*, 311, & 312, reported to federal, state, county, and local EPA-related agencies by March 1 annually.

SARA, Section 304

Emergency Procedure for Spills & Releases. For any of the 775 listed chemicals spilled or released at or greater than its Reportable Quantity (RQ), EPA requires that facility personnel immediately follow up with the National Response Center. This section is screened by the client’s Environmental Management System.

Toxic Release Inventory Reporting, SARA, Section 313

Required by July 1 annually, the facility must report toxic releases of 800+ chemicals if three criteria are met: (1) 10 or more FT employees; (2) SIC Codes between 2000-3999 (plus 7 additional industry sectors named by EPA); and (3) Releases exceeding 25,000 lbs. or 10,000 lbs. (depending on how said chemical(s) are used at the reporting facility) in the previous calendar year. Selected states require additional industry sectors &/or lower thresholds.

Per- and Poly-FluoroAlkyl Substances (PFAS) (“Forever Chemicals”)

Analysis of 10,690 toxic chemicals is executed by the client’s Environmental Management System.

Stormwater Runoff Permitting & Training (All States)

Permitting is achieved by submittal of a Notice of Intent (NOI), plus developing a site-specific Pollution Prevention Plan of the facility. In addition, the facility must identify its Water Priority Chemicals (among 670 candidates) – by quantity and location – plus training of selected employees and the Pollution Prevention Team (PPT).

Spill Prevention & Control & Countermeasure (SPCC) Plan & Training

EPA mandates any facility that maintains an oil-related product inventory of 1,320 gallons or more must develop an SPCC Plan, to be updated every five years or when a facility modification occurs. Employees designated as “oil handlers” must be trained annually on the Plan’s contents. It must be noted that EPA assesses entities based on capacity of containers on site, rather than just product quantities.

Process Wastewater Discharge Monitoring Reporting (DMR), aka Industrial Wastewater Permitting

For companies using huge amounts of water as a part of their processes, they must acquire and manage a water permit and submit reports, as required by the municipality.

Air Permitting (Major / Minor Source; Synthetic Minor; Permit-by-Rule; ROSS)

There are many forms of air permitting, depending on a company’s operations and emissions to the air. Vanguard handles them all, which means an application must typically be submitted to the agency having jurisdiction over the facility, while conditions for the permit approved must be met and managed on an annual basis. A “lifetime permit” does not mean an allowance of unlimited emissions for an unspecified period of time.

Risk Management Plan (112r) (RMP)

Akin to OSHA’s Process Safety Management (PSM), EPA’s RMP is designed to prevent industrial disasters by screening 258 Highly Hazardous Substances (HHSs) against Threshold Quantities (TQs) assigned to each chemical. Protocols and training are designed to prevent disasters that could harm employees, as well as the community-at-large.

Emissions Inventory Reporting (All States) per EPA’s Air Emissions Reporting Rule (AERR)

There are 187 Air Toxics, aka Hazardous Air Pollutants (HAPs), for most states; more for CA, GA, IL, OH, OK, WA), which require an annual state-administered report. The U.S. Environmental Protection Agency (EPA) published its proposed updated Air Emissions Reporting Rule (AERR) on August 9, 2023 and EPA expects to finalize the rule in Summer, 2024. This update aims to improve EPA’s collection of emissions data critical for air quality and risk analyses, among other regulatory activities.

RCRA Hazardous Waste Management Plan & Reporting

Following EPA’s Resource Conservation and Recovery Act (RCRA) of 1976, this law regulates how hazardous waste is managed in the U.S. Following are issues related to a facility’s requirements, based on such designations as Large Quantity Generator (facilities generating over 2,200 lbs. of hazardous waste in any given month) or Small Quantity Generator (facilities generating 220 to 2,200 lbs. of hazardous waste in any given month).

  • RCRA Hazardous Waste Training
  • Quarterly, Annual, & Biennial Waste Reporting (Selected States).
  • Hazardous Waste Contingency Plan for Large Quantity Generators (LQGs).
  • Emergency Response Plan for Small Quantity Generators (SQGs).
  • Re-Notification Reporting (Selected States) for LQGs…Even-numbered years; & SQGs…Every four years.
  • Oil Spill Prevention & Response Act (OSPRA).
  • Source Reduction & Waste Minimization (AZ; CA; GA; TX; WA).
  • Pollution Prevention Planning (P2P) (AZ; CA; GA; TX; WA).

Chemical Data Reporting (CDR) under EPA’s Toxic Substances Control Act (TSCA)

Every four years, the EPA requires a report regarding the manufacturing and/ or import of over 84,000 toxic chemicals. Reporting is completed for toxic chemicals manufactured or imported in annual quantities of 25,000 lbs. or 2,500 lbs., as evaluated in a baseline compliance year, as well as the three previous years.

Environmental, Social, and Governance (ESG) Reporting

ESG reporting constitutes the comprehensive disclosure of a company’s environmental, social, and governance initiatives, performance, and impact. ESG reports provide stakeholders with valuable insights that can inform decision-making, highlighting potential opportunities and risks that might affect the valuation of a company.

Federal Insecticide, Fungicide, & Rodenticide Act (FIFRA)

Pesticide Reporting by March 1 annually.

Environmental Site Assessment…Phase I

For Commercial Real Estate Valuations &/or Transactions, with EPA’s newly-required ASTM E1527-21 Performance Standard. Phase II requires sampling and analyses when contamination is discovered.

Restriction of Hazardous Substances (RoHS) and Waste of Electric and Electronic Equipment (WEEE) Reporting

(for 8 U.S. States)

This U.S. law stands for "The Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment." RoHS requires producers to remove specified hazardous substances from their EEE, such chemicals as lead, cadmium, mercury, hexavalent chromium, polybrominated biphenyl (PBB); and polybrominated diphenyl ether (PBDE) used in flame retardants. These bad actors are found in products like electronic toys, speakers, earphones, printed circuit boards, lighting, smart watches, kitchen appliances, phones, tablet computers, electric motors, and more. Initially required by a directive in the European Union, this U.S. law is now required in the states of CA, IL, IN, MN, NJ, NY, RI, and WI, with potentially more states to be enacting similar legislation in the future.

Hazardous Materials Inventory Statement (HMIS) (Selected Cities)

Additional to SARA Reporting as required by municipalities to track and prepare for emergency response per criteria as mandated by agency of record.

Hazardous Materials Management Plan (HMMP) (Selected Cities)

Additional to SARA Reporting as required by municipalities to track and prepare for emergency response per criteria as mandated by agency of record.

CalEPA (California-Specific)

  • Hazardous Materials Business Plan (HMBP): Includes SARA 302 Extremely Hazardous Substances. As opposed to SARA Reporting in the other 49 states, California’s HMBP is reported annually to the Certified Unified Program Agency (CUPA) having jurisdiction over reporting entities, and by regulation, is inspected on a triennial basis.
  • Proposition 65 Implementation & Training: Facilities located in California must alert employees by poster and training of the potential exposure to one or more carcinogens, mutagens, and teratogens, totaling as many as 1,013 life-threatening and/or genetically harmful chemical hazards.
  • Proposition 65 Consumer Products Screening / Labeling (All Nations and All States): All entities external to the State of California must properly label its products being shipped into California if its product(s) contain any Proposition 65-regulated carcinogens, mutagens, or teratogens in excess of “safe harbor” limits assigned to chemicals on a chemical-by-chemical basis.
  • Stormwater Reporting by July 15 Annually: California requires stormwater regulations that supersede most other states. A Qualified Industrial Stormwater Practitioner (QISP) is required, along with a report via the Stormwater Multiple Application and Report Tracking System (SMARTS), the agency of record, even if a facility is exempt from California’s stormwater regulation. A Stormwater Pollution Prevention Plan, an analysis of EPA’s 670 Water Priority Chemicals, training for materials handlers, plus an array of analytical mandates are required annually.

Florida-Specific – Environmental Resource Permit (ERP)

This program regulates activities involving the alteration of surface water flows, including new activities in uplands that generate stormwater runoff from construction sites, as well as dredging and filling in wetlands and other surface waters. ERP applications are processed by either the Florida Department of Environmental Protection (FDEP) or one of the state’s Water Management Districts (WMDs), in accordance with the division of responsibilities specified in operating agreements between the FDEP and WMDs.

Michigan-Specific – Michigan Incident Prevention Plan (MIPP)

The MIPP follows the EPA’s SPCC Plan, but requires a more stringent slate of activities and training than the traditional SPCC required in other states. Michigan specifies salt as a pollutant under its MIPP.

*15 U.S. Laws require the execution of the Aggregate Total Ruling.