When Robin Fleming of Anvl got together with Luke Jacobs (co-founder & CEO) and Brandon Barlow of Encamp to talk about digital transformation for EHS teams and environmental compliance, their Campfire Session was more than informative.

It was a real-world look at how digital transformation continues to change the way work gets done — including environmental compliance.

Robin is Anvl’s co-founder and CEO. She’s also an authority on digital technology and how businesses use it to more effectively collect, analyze, and apply data of all kinds. And not surprisingly, Anvl’s platform for data management mirrors the Encamp platform and its powerful combination of data management and automation for environmental compliance and reporting.

Both platforms are digital transformation at its best. Watch the video to learn why.

Making the move

Digital technology dates back to 1970s and the Digital Revolution. But for many EHS teams and environmental compliance, the digital movement is still in the early adoption stage. Some takeaways from the video to lead your EHS team through digital transformation (DT):

Start your digital transformation journey

Associated Encamp blogs

EHS Digital Transformation: SaaS is a Good Thing

EHS Digital Transformation: The Need for New Mindsets

EHS Digital Transformation: The Tech Vendor Partnership

EPCRA Tier II Reporting. Working Remotely. Thriving!

About Anvl

Anvl helps unlock critical data in real-time by connecting frontline workers and supervisors through a single, easy-to-use platform. The Anvl solution includes real-time data collection, in-the-moment guidance, alerts and analytics — supporting positive changes, productivity improvements, & cost and time savings.

For environmental compliance, continuous EHS training is a must. According to many EHS professionals Encamp works with, in fact, it’s a constant priority.

Such EHS training is vital for RCRA and EPCRA Tier II reporting. EHS professionals also rely on training to keep up with regulatory requirements. Even the latest industry developments and trends fall under the EHS training umbrella.

On Encamp’s recommendations list for EHS training resources, these five are at the top. (Thanks to our director of customer success for the assist.)

Free webinars from EHS Today

EHS Today is a leading magazine for EHS management professionals in the United States. You can also say their website is a living encyclopedia for EHS industry news. And without question, the webinars from EHS Today are excellent tools for EHS training.

Both upcoming and archived, their webinars offer information and analysis from industry leaders. They also address a range of environmental compliance, sustainability, and risk management topics. One webinar of note is “State of the EHS Industry: Exploring the Results of the EHS Research Study.” The webinar is archived from April 2020, but it’s still a relevant for EHS training.

You can access the full library of EHS Today webinars here.

Resources from the EHS Daily Advisor

The EHS Daily Advisor from BLR is another great website for all things EHS. They start with their newsletter as a daily source of EHS industry news and insights. A library of reports, eBooks, white papers and other materials also make for valuable EHS training resources.

One resource for EHS leaders that caught our eye? The EHS Leadership in 2021 report.

See the full list of other free EHS Daily Advisor resources here.

McCoy and Associates white papers

When it comes to RCRA training, McCoy and Associates are in a league of their own. McCoy is regarded for their in-depth RCRA training seminars, which can get costly. But what many EHS professionals don’t know is that McCoy also offers a library of free white papers. These papers cover virtually every waste topic imaginable. Consider them premier EHS training resources for RCRA.

You can find McCoy’s white paper library here.

Free health & safety classes from Alison

Alison is one of the world’s largest free learning platforms for education and skills training. We’ve included them on our list for their ISO training courses for environmental management. They additionally offer a strong selection of Health & Safety training classes. Course ratings serve as guidelines for which courses are worth considering.

Current class offerings are listed here.

Free webinars from NAEM

NAEM is the National Association for EHS&S Management. And environment, health, safety and sustainability (EHS&S) leaders can take advantage of the organization’s many professional development opportunities. Although various NAEM events require a membership, however, many of their resources and webinars for EHS training are free.

Register for upcoming webinars and access their library of archived webinars here.

EPCRA, in full, is the Emergency Planning and Community Right-to-Know Act. The United States Congress passed EPCRA and its various EPCRA Sections as a federal law in October 1986. The law was a response to multiple accidental chemical releases that had recently occurred worldwide.

One of the most tragic incidents was the release of methyl isocyanate in Bhopal, India. The release, which occurred in December 1984, killed 3,800 people. Others in the immediate and surrounding areas suffered serious illnesses. In response, Congress passed EPCRA to prevent a similar disaster in the United States.

EPCRA Sections and their four key responsibilities

EPCRA entails four core responsibilities for chemical use and storage, classified by Sections. These EPCRA Sections apply to all regulated facilities within a local jurisdiction.

EPCRA Tier II

EPCRA Tier II is housed under EPCRA Section 312. For regulated facilities, EPCRA Section 312 Tier II requirements dictate that they submit an annual inventory of hazardous chemicals onsite that surpass a stated quantity threshold. Thresholds are federally mandated, but can be superseded by state or local requirements. Inventories are submitted to the facility’s State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC), and the local fire department.

The details of EPCRA Tier II reporting can get murky. And often confusing. Encamp’s VP of Compliance and Customer Success breaks down the key aspects EPCRA Tier II reporting requirements here to help your business comply with total confidence.

Who must report?

On the federal level, any regulated facility in the U.S. that stores or handles more than 10,000 pounds of hazardous chemicals must submit an annual Tier II inventory report. Facilities storing or handling an Extremely Hazardous Substance (EHS) of 500 pounds or its Threshold Planning Quantity (TPQ, whichever is lower) are also required to submit the annual Tier II inventory.

As defined by the EPA, hazardous chemicals are “substances for which a facility must maintain a Safety Data Sheet (SDS) under the Occupational Safety and Health Administration (OSHA) Hazard Communication Standard.” This standard establishes the criteria used to identify a hazardous chemical. OSHA defines a hazardous chemical as any chemical that can “cause a physical or health hazard.” Common chemicals that many facilities store on-site, such as antifreeze, ethanol, diesel fuel, and propane, are subject to this reporting.

EHSs can be tricky

While EHSs have a general threshold of 500 pounds, thresholds can be lower for specific substances dependent on the TPQ published for the chemical. TPQs are based on “acute mammalian toxicity and potential for airborne dispersion and represent those quantities of substances that can cause significant harm should an accidental release occur.” See the list of EHSs and their corresponding TPQs in Appendix A of the EPA’s List of Lists. There are many common chemicals considered to be EHSs that might surprise you. Examples include anhydrous ammonia, sulfuric acid, formaldehyde, and hydrogen peroxide (if the concentration is over 52%).

Retail gas and diesel stations share a common EHS threshold exemption. Higher thresholds apply for retail gas and diesel stations if their fuel storage tanks are located entirely underground, and if the tanks are in compliance with all applicable underground storage tank (UST) requirements set by the federal, state, and local government. For a retail gas station, the threshold for gasoline is 75,000 gallons and the threshold for diesel is 100,000 gallons. (Read more on exemptions and relaxed thresholds in our associated blog on Hazardous Chemical Inventories.)

How to comply

Based on the EPCRA Tier II reporting requirements we’ve detailed thus far, you’ve determined that your facility is required to report under EPCRA. So what’s the next step?

Under Section 311 of EPCRA, for hazardous chemicals stored onsite at or above the thresholds,  facilities must submit SDSs to their State Emergency Response Commission (SERC), Local Emergency Planning Committees (LEPCs), and local fire department. Unless your state or local government determines otherwise, submitting an SDS for a hazardous chemical is required just once; thereafter, SDSs are required only for new chemicals stored or handled at a facility.

Submitting an EPCRA Tier II form

On an annual basis, regulated facilities are required to submit an inventory of the chemicals that meet the definition of a hazardous chemical and exceed the defined reporting threshold. By law, EPCRA Tier II forms are due on March 1 each year.

Of note, while the EPA has published a generic EPCRA Tier II form to submit inventory reports, each state in the U.S. has developed its own version of the form. Some states naturally require state-specific requirements on their Tier II form. They also require the information to be submitted online through the state’s own portal or via email. Otherwise, the EPA and state agencies request the same core information for EPCRA Tier II reporting, including facility information (address, NAICS code, number of occupants, etc.) and contact information (emergency contact, owner/operator contact, and Tier II contact).

In addition to general facility information, Tier II forms also sometimes request other facility specific questions. For example, if your facility is subject to the Risk Management Program (RMP) through the EPA, you’ll need to indicate that and provide your facility’s RMP ID#.

Chemical inventory information

The chemical inventory section of an EPCRA Tier II form is much more detailed. To ensure compliance, you must provide the following information on the hazardous chemicals you’re reporting:

Several states request more information beyond these requirements. For example, Maine requires the mode of shipment for a hazardous chemical, the frequency of shipment, maximum capacity per single vessel, average shipment quantity, and other shipping criteria. In another example, Ohio requests the total number of EHS and hazardous chemicals to be included in its EPCRA Tier II report.

Facility site plans

Along with the chemical inventory information, some states additionally require you to submit facility site plans. Such plans show where chemicals are stored in the facility, and where emergency exits, fire extinguishers, and nearest water source are located. Site plans are crucial for first responders who need to know these details before they enter a facility in an emergency situation. Check with your state to see if a facility plan is required as part of your EPCRA Tier II submission, what needs to be on the plan, and the file format it should be in.

Fees

Once required Tier II reporting information and documents are uploaded to a state’s reporting portal, several states require facilities to pay a filing fee per report. Fee amounts vary based on a state’s criteria. For instance, states including Louisiana, Minnesota, and Pennsylvania bill your facility per each chemical being reported. Other states, like New Jersey, bill the facility by the number of employees. Many state portals accept payment of the fees directly, whereas other states send your facility a bill and require you to pay by check or credit card. Depending on your state, the LEPCs may charge fees as well.

EPCRA Tier II due date

When is all of this information and documentation due? Again, the annual Tier II report is due March 1, which is the deadline set federally. All 50 states follow this deadline except for specific jurisdictions in California. California is divided into Certified Unified Program Agencies, or CUPAs for short. Some CUPAs require this information to be submitted at different times during the year. Also in New Jersey, public and private entities have different due dates. For the most part, states require the information before March 1. If your information is submitted late or not submitted at all, you could be subject to enforcement actions or fines.

Raise your hand if you enjoy dealing with 50 different state portals every Tier II season.

We didn’t think so, because not many people in Tier II reporting roles do. Which is why we say welcome to Encamp’s newest version of our Tier II Dashboard.While our platform has always made reporting intuitive and efficient, it now makes the process even faster, simpler, and more accurate. Call this enhanced dashboard Tier II reporting on steroids. And then turn your imagination loose.

Tier II Dashboard Overview

First, for reporting and status tracking, envision logging into one environment that takes the place of all the different systems from all 50 states. That’s benefit #1. Across your organization, every person involved in Tier II reporting accesses the same dashboard and uses the same reporting and tracking tools. Benefit #2.

At the executive level, leaders get a full oversight view of every activity: Reporting percentage until completion, the number of days to deadline, facilities that have already filed, and ones that still need to start the process. Encamp then completes all submissions and pays the fees on your company’s behalf, including for SERCs, LEPCs, and even fire departments. Big benefit.

For every facility in your company, our Tier II platform lets you sync with portals in every state. Then more simplicity takes over.

In a streamlined and consistent manner, you complete every Tier II reporting detail. After that, Encamp completes your submissions to every regulatory agency for you, again on your company’s behalf. It’s your company’s Tier II program at its finest — with countless benefits to eliminate headaches.

We’ve even made sure our Tier II platform puts a built-in knowledge base at your fingertips. It answers questions about everything reporting, Tier II requirements, includes training videos, and offers helpful tips & tricks.

Tier II reporting that’s fast, simple, accurate. At Encamp, our goal has always been to make your life easy for the Tier II season. Our enhanced Tier II Dashboard now makes it that much easier.

Happy reporting!

Welcome to another EHS Moment from Encamp…

This time I want to talk about two things that don’t even seem to fit in the same sentence: My interest in shoes, and my interest in the environment and sustainability. Because what do shoes have to do with the environment, right?

The answer is, thanks to Nike, shoes now have everything to do with the environment and sustainability.

Earlier this summer Nike released its new Space Hippie shoe collection (the new line dropped in July), and they’re reported to be their lowest carbon footprint shoe ever made. Space Hippies consist mostly of recycled material — yes, they’re literally made of trash! — and Nike offers four models to choose from. (My favorite is the Space Hippie 01, which provides the traditional lace-up with the one-of-a-kind Nike Crater Foam outsoles.)

With Nike leading the way, shoe companies’ efforts towards waste-free carbon neutrality and keeping sustainability at the top of mind is a huge step. Nike says as much in promoting their new shoes and the approach they’re taking to producing them.

“Space Hippie,” as Nike puts it, “is the result of sustainable practices meeting radical design.”

When you take a closer look at Space Hippies, the material the shoes are made of stands out. Overall, the fabric is 85% to 90% recycled, with 50% of that coming from plastic bottles and other plastic waste. Along with recycled plastics, 25% of the shoes’ material consists of old consumer goods, like t-shirts. The remaining material is a mix of Nike yarn or other leftover materials in their factories.

So that’s how you have the upper half of Space Hippies. On the bottom half, their cushion sole is made of Nike Zoom X foam, or what Nike calls crater foam, of which 15% is made from grain rubber. That’s where you get the Nike proprietary mix and little flecks and specks inside the foam, which really stands out stylistically. As a shoe enthusiast, I think the new Space Hippies are really good-looking shoes.

Yet while making shoes from recycled materials is a positive step for Nike and the environment, it isn’t necessarily a new concept for the global shoe and sportswear maker. To date, Nike has already been recognized for diverting roughly 1 billion plastic bottles from landfills to be recycled for greater sustainable good.

Beyond Nike, other shoe companies are also now escalating their efforts toward waste-free carbon neutrality and sustainability in the materials they use. On that list: Saolo, Indosole, Timberland, North Face, MOVMT, and Nike competitors adidas and Converse, among others. It’s a move in the right direction both for our environment and for the business world itself.

These efforts also reinforce what we always say at Encamp: What’s good for business is good for the environment.

Today I want to talk about a company that is quickly becoming one of my favorites — and not just for the items they make. The company is Diageo, and for the record they’re the spirit company that produces Johnny Walker, Guinness, and Smirnoff.

Now, making scotch, ale and vodka is all well and good. But environmentally, what Diageo does is they always keep sustainability top of mind in almost everything they do. The company is known for their industry leading environmental goals and achievements as much as they are for the spirits they sell.

This year, in fact, Diageo announced they’ve achieved most of their sustainability goals that they set back in 2008. They’ve cut their greenhouse gas emissions in half across its direct operations, improved its water efficiency by 46%, and achieved zero waste to landfill at all production sites and offices.

So kudos to Diageo.

The first 100% plastic free paper-based bottle

A few months ago, the company also announced they’ve created their first 100% plastic free bottle made of paper products.

Ok, ok, I know what you’re thinking. We’ve all used paper straws, and not all of us are fans of paper straws. As you drink more, they tend to break down. I hear you.

But by a paper bottle, I mean paper based. Diageo’s new bottle will be made entirely from sustainably sourced wood to meet food-safe standards and will be fully recyclable in standard waste streams. It will debut with Johnny Walker in early 2021.

Likewise, this new bottle will allow other brands to rethink their packaging designs and go plastic free. Safe to say, Diageo is pushing sustainability and environmental innovation — which is what we all want.

Look for more of our daily EHS Moment videos on your favorite social channel. And please, give them a like or leave a comment. You can also watch the entire video series on the Encamp YouTube page.

Remember, what’s good for business is good for the environment.

We call it Better for You, Better for Nature. PR campaign? Nah. Encamp is just doing its part to help replenish the environment by planting trees.

And while it’s only one tree at a time, our count is already closing in on 3,300 new saplings. (Most likely more after this is posted. See the counter at the end of our Home page.)

Here’s how it works, and why we’re doing it.

The gist is, for every Tier II report that gets filed through our system for EHS compliance, Encamp makes a donation to have a tree planted somewhere in the 50 states. So first, thank you to every one of our customers who file a Tier II report from those states. Please keep them coming.

The next big thanks go to our friends at One Tree Planted, who do all the critical work. They grow new saplings, plant them, maintain them, and then tell how these new trees are benefitting our planet.

Quick fact from One Tree’s site: Trees help clean the air we breathe, filter the water we drink, and provide habitat to over 80% of the world’s terrestrial biodiversity. They also absorb harmful carbon from the atmosphere and are key ingredients in 25% of all medicines. Trees even provide jobs to more than 1.6 billion people around the world.

About One Tree Planted itself, they’re an environmental charity “dedicated to making it easier for individuals and businesses to give back to the environment.” Their mission is to let companies like Encamp help create a healthier climate, protect biodiversity, and aid reforestation efforts around the world. “All by planting trees!”

“We’ve been committed to aligning our business goals with environmental goals at Encamp from the very beginning,” said Luke Jacobs, Encamp’s co-founder and CEO. “Even before we had paying customers, we were committed to the idea of planting a tree for every Tier II report we file.”

This allows Encamp to cut down on paper costs, Jacobs explained, both by digitizing paper-based processes for its customers and by going the extra mile to get more trees planted across the country.

“Our mission at Encamp aligns well with the goals of One Tree Planted, and we’re excited to keep striving towards a world where good for business can equal good for the environment.

One Tree Planted started in 2014 and planted 150,000 trees its first full year. In 2019, they were able to get 4 million more trees in the ground worldwide.

One tree at a time, we’re proud to be contributing to that number.

Where do we even start? COVID-19 and the coronavirus pandemic are still running rampant. Masks and plastic gloves and face shields have become staples of our daily wardrobe. And safe to say, most people now know as much about Personal Protective Equipment — PPE — as any medical professional ever has.

Right now, until a proven vaccine gets here for COVID-19, PPE is our best protection. You know, wash your hands, distance… wear a mask. But the coronavirus and PPE are also converging on a different path. And the environment is suffering because of it.

Some numbers:

Earlier this year, the World Health Organization projected the global production of PPE supplies would need to increase by 40% every month to keep pace with the pandemic. Translated, that means 89 million new masks, 76 million pairs of gloves and 1.6 million pairs of goggles. Every. Month.

Consultants at Frost & Sullivan additionally predicted the US alone could generate an entire year’s worth of medical waste in just two months. Credit the pandemic again.

Yet governments at the international, national, state and local level are still trying to decide where these millions of products will end up after they’re disposed of.

Not a new problem

Although COVID-19 has intensified the PPE issue, disposing of plastics in general was a problem long before the pandemic.

“PPE is just the tip of a mountain of toxic plastic waste that we’ve been ignoring for years,” said Sian Sutherland, co-founder of A Plastic Planet. A 2020 study co-authored by the not-for-profit group along with the sustainability firm, SystemIQ, backs him up, and it cites the ocean as taking the brunt.

The study forecasts that, by 2040, 29 million tons of plastic will find its way into oceans worldwide every year if governments and industry don’t take immediate and significant action. That annual rate would be nearly triple of what it is now.

“A new breed of single-use plastic”

“PPE is a whole new breed of single-use plastic that we didn’t have even in January,” said Claire Potter, a marine plastic expert in the United Kingdom. “We’re now seeing it being washed up onto the beaches — it’s coming in, we’re also seeing it left on the beaches as well.”

For PPE itself, the underlying culprits are that most of these supplies are used only once and often contain various types of plastics. (Prior to the 1980s, most all PPE was reusable.) These plastics can range from polypropylene and polyethylene in face masks and gowns to nitrile, vinyl and latex in protective gloves.

In many western countries, at least, companies have long incinerated hazardous medical waste like PPE on site to prevent the transmission of infectious disease. “Other than burning it, there is nothing really we can do,” said Sander Defruyt, head of the plastics team at the Ellen MacArthur Foundation. “It’s designed to be waste.”

So now, add millions of citizens to the thousands of medical staff who must wear single-use protective equipment to guard against COVID-19, and PPE is everywhere. And if it isn’t being incinerated, it’s showing up in conventional waste streams or being dumped in the open air.

“If it’s on your streets, it’s going to the ocean because it’s one rainfall away from getting into a storm water system, and then being carried into a river and into the ocean,” warned Mark Benfield, a zooplankton ecologist and professor at Louisiana State University.

Or as a recent WWF report puts it, even if only 1% of PPE masks are disposed of incorrectly, some 10 million of them could infiltrate the natural environment each month — polluting rivers, waterways and oceans around the world.

What the regulatory agencies recommend for PPE

To properly dispose of used PPE “with potential or known COVID-19 contamination,” recently updated OSHA guidelines advise waste disposal workers to handle office and home solid waste just as they would any other non-contaminated municipal waste.

Typically, OSHA says, managing such waste “does not require special precautions beyond those already used to protect workers from the hazards they encounter during their routine job tasks in solid waste and wastewater management.”

Guidance from the World Health Organization (WHO) says employees should place their used PPE in a bag, seal the bag tightly, and place it in a sturdier garbage bag for pick up.

A medical setting is much different and far more regulated, however. In this case, the CDC and OSHA do not consider COVID-19-contaminated material to be a Category A infectious substance. Such material is still managed as regulated “medical waste.”

The general guidance OSHA uses for medical waste is if the person or item is “known or suspected” to be hazardous. This especially applies to single-use PPE. As OSHA says, it is the generator’s responsibility to determine if a waste is known or suspected to be hazardous and, in the event of COVID-19, infectious.

In industrial settings, under most circumstances PPE waste is not considered regulated medical (infectious) waste and can be treated as solid waste. According to the CDC and the WHO, waste materials that are not assumed to be contaminated do not require any special precautions. and can be managed as they typically would for the flu.

Waste that is indeed suspected or known to be contaminated with COVID-19 should be managed in accordance with standard CDC and OSHA procedures and handled like other regulated medical waste.

What now?

So what does this collision course of COVID-19, PPE and the environment mean for the EHS industry? Aside from a new type of waste to worry about, expect new regulations and PPE disposal programs to be developed on a continuing basis.

The Department for Environment, Food & Rural Affairs (Defra) in the UK, for instance, recently issued new guidance on the PPE topic. Among multiple issues in their document, Defra addresses the benefits of reusable face masks, how best to dispose of PPE if you own a small business, and cleaning up waste in non-healthcare settings.

In Las Vegas, the Venetian Resort has partnered with TerraCycle to create a face mask recycling program. And at MIT and Brigham and Women’s Hospital, researchers have designed a new type of reusable face mask that can be easily sterilized and washed.

This is interesting, too. Beyond PPE, researchers at EPA and the CDC are developing (and already applying) methods for measuring SARS-CoV-2 levels in wastewater. SARS-CoV-2 is the strain behind COVID-19. Public health officials will be able to use these methods to determine infectivity, persistence, and treatment efficacies related to SARS-CoV-2 in wastewater in their communities.

Thus far, preliminary findings from the two agencies show that monitoring wastewater for the presence of SARS-CoV-2 can be a sensitive early indicator of low levels of COVID-19 infections. At the same time, such monitoring in wastewater could also signal decreasing levels of infection within a community.

Until the coronavirus pandemic subsides, EHS practices will be just as critical as the efforts to discover new ways to treat and prevent COVID-19.

Meantime, wash your hands, distance, wear a mask… and dispose of it wisely when the time comes.

Contact us. We can help with your EHS compliance in the battle to beat COVID-19.

Lead-acid batteries are known to break from time to time. When they do, and the electrolyte begins to leak from its casing, you’ll need to know how to react immediately and what the next steps are.

Do I need to do a 304 Notification?

EPCRA Section 304 is the Emergency Release Notification section of EPCRA. You are subject to this rule if your facility “produces, uses, or stores a hazardous chemical” and you “release a reportable quantity (RQ) of any EHS or of a hazardous substance as defined by the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) at your facility.”

Sulfuric acid is the main chemical of concern in regards to 304 notifications. The RQs for 304 notifications are listed in Appendices A and B and also on the List of Lists. For sulfuric acid, the RQ is 1,000 pounds. It may be hard to quantify the total gallons or pounds of the spill, but if the battery shell is left with only the plates inside, you can work backwards to determine if the spill has exceeded the RQ based the percentage of sulfuric acid on the SDS.

Who do I notify?

Once you’ve determined that the spill has exceeded the RQ and you are subject to 304, what’s the next step?

The federal regulations state that you must notify the “SERC and LEPC of any area(s) that are likely to be affected by the release.” If the substance is also listed on the CERLCA list, the National Response Center (NRC) must be notified as well. The NRC’s report hotline number is (800)424-8802. EPA has also published a list of State Contact Information for 304 Notifications, which you can find here.

What to Include in the Notification

EPA’s website states you must include the following information. Check with your state as well, in case they require additional information.

The regulations say that gathering this information should not impede the notification on emergency response. If you have hazardous chemicals at your facility, it’s best to prepare for this type of notification well ahead of a spill. Many facilities choose to post this information by a facility phone or in an accessible area so the information can be gathered quickly. The immediate notification should be conducted orally, over the phone.

Follow-up

After the initial notification is made and the release has been contained, a follow-up written report must be submitted to the SERC and LEPC. Unless this event occurred during transportation or from storage incident to transportation, the written follow-up must be submitted as soon as practicable. In the written notice, you must provide and update the information that was reported in the immediate notification and include the following additional information:

Source: 40 CFR 355.40(8)(b)

EPA does not have a prescribed format for this notification, and only states that it should be written. Check with your SERC to see if they have a required or preferred format. For example, Indiana requires the 304 follow-up notification to be submitted via their Tier II Manager portal. Some states, like Texas, have issued a timeframe for the follow-up notification.

Cleanup

In the midst of notifying the appropriate parties and keeping everyone safe, cleaning up the spill is another task you’ll need to complete to mitigate the situation. Most SDSs provide cleanup information in case of a spill or release, so be sure to check those well in advance. It’s recommended to have the proper PPE and spill kit items handy in case of an emergency, so you can clean up the spill quickly. Some items that you may need to clean up the spill are:

When the absorbed acid and cleanup material are packaged up into a bucket or drum, be sure to label it appropriately. If the acid was neutralized, it’s possible the waste can be considered non-hazardous, but be sure to do your due diligence with analysis, if necessary. If the acid wasn’t neutralized and just absorbed, the waste can be considered hazardous depending on your state’s regulations. For instance, California considers any solid when mixed with an equivalent weight of water that produces a liquid that corrodes steel at a rate greater than 6.35 mm per year to be hazardous.

Once packaged and properly labeled, work with your hazardous waste contractor to pick up the containers for disposal. The broken lead-acid battery casing might be able to be salvaged. Most hazardous waste treatment companies have contracts with lead-acid battery recyclers, so they can arrange for recycling if it’s possible.

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