COMMUNITY Right to Know Survey due March 1, 2017
Who has to do this?
Facilities in certain industrial classifications defined by North American Industry Classification System (NAICS) Codes are required to submit an annual Community Right to Know Survey (CRTK Survey). Many companies believe they are exempt from reporting requirements and have not submitted a CRTK Survey or an Exemption form.
In the reporting year of 2015, this has resulted in the Department of Environmental Protection (DEP) enforcing action against all entities in violation for
failure to reporting with an issuance of a $1,000 penalty.
Most companies with few exceptions have to submit a CRTK Survey. Since the NYC RTK Law has set very low reporting thresholds for many substances even small quantities may need to be reported. Compliance is required if any hazardous substances meets or exceeds the appropriate reporting threshold. Mixtures will also need to be reported depending on their contents. Other Right to Know requirements include reporting spills at the facility, designating a facility emergency coordinator and labeling hazardous material containers properly.
Companies in the State of New York comply with federal chemical inventory reporting requirements.
What are your next steps?
For more information and a free consultation, contact PHASE Associates
to determine if your company is required to submit a CRTK survey for reporting year 2016. We can also discuss your existing Hazard Communication program or assist in updating your company's current program; updating and/or creating labeling for hazardous material containers; updating and developing existing SDS and provide training for your workers.