Sustainability solutions for a global economy
Since 1990, Cornerstone (formerly SARA Services, 1990-95) has provided superior environmental and safety compliance solutions to the regulated community, and services clients throughout North America, Europe and Asia. We offer enterprise solutions for environmental regulatory compliance, worker safety, quality systems and custom software solutions. As part of our commitment to ensure our clients receive the highest level of services, our Quality Management System is certified to conform with the requirements of ISO 9001:2015.
NESHAP Air Regulations Update (Once In Always In Guidance Change)
The U.S. EPA has issued a guidance memorandum withdrawing the “once in always in” policy for the classification of major sources of hazardous air pollutants under section 112 of the Clean Air Act. With the new guidance, sources of hazardous air pollutants previously classified as “major sources” may be reclassified as “area” sources when the facility limits its potential to emit below major source thresholds.
TSCA Inventory Notification (Active-Inactive) Final Rule published 8/11/2017 in Federal Register (40 CFR 710)
Chemical manufacturers, processors, distributors and importers are subject to chemical control requirements under the U.S. Environmental Protection Agency’s (EPA) Toxic Substances Control Act (TSCA). TSCA provides EPA with authority to require reporting, recordkeeping, testing requirements and restrictions relating to chemical substances and/or mixtures.
Many original equipment manufacturers (OEM’s) are issuing requests that ask their suppliers (which may include Processors and Users) to seek confirmation that any chemical substances used in the supplier’s product(s) [via Bill of Materials] and related substances are reviewed to ensure that no chemicals are inadvertently left off the Active Inventory.
As part of these requests, Suppliers are being asked to take steps to ensure the EPA Inventory Notification process is completed by February 2018 or, at the least, prior to October 5, 2018, for all non-exempt chemical substances used throughout your supply chain. This includes many manufacturers that have requested their vendors coordinate with upstream suppliers (chemical manufacturers and importers) to ensure they too are taking steps to comply in a timely manner.
As a Processor or User, if you have received such a request or anticipate a request of this nature from a customer, it is critical to be thorough in your approach. CEHS can assist. Please give us a call to discuss your specific needs.