EPA's Reporting Requirements for H2S Now in Effect

Lifting the administrative stay for the Emergency Planning and Community Right-to-Know Act section 313 toxic chemical release reporting requirements means affected industries' first reports will be due July 1, 2013.

A longstanding EPA hold on industry's reporting requirements for hydrogen sulfide has been lifted, which means that utilities, chemical companies, and other industries that manufacture, process, or use hydrogen sulfide in amounts above reporting threshold levels must begin reporting as required by the Emergency Planning and Community Right-to-Know Act's section 313. Hydrogen sulfide was added to the EPCRA section 313 list of toxic chemicals in a final rule published in December 1993, but EPA issued an administrative stay of the reporting requirements on Aug. 22, 1994, and only now is lifting it.

EPA stated in February 2010 that it planned to lift the stay.

Hydrogen sulfide was added to the section 313 list of toxic chemicals, in response to a petition from the Natural Resources Defense Council and the governor of New York, under the criteria of EPCRA section 313(d)(2)(B) (chronic human health effects) based on chronic neurotoxic effects in humans and under EPCRA section 313(d)(2)(C) (environmental effects) based on acute aquatic toxicity.

EPA's notice in the Federal Register says the agency doesn't believe an exposure assessment is appropriate for determining whether hydrogen sulfide meets the criteria of EPCRA section 313(d)(2)(B) or (C), so the administrative stay should not be continued for lack of an exposure analysis. "Hydrogen sulfide can reasonably be anticipated to cause serious or irreversible chronic human health effects at relatively low doses and thus is considered to have moderately high to high chronic toxicity. EPA does not believe that it is appropriate to consider exposure for chemicals that are moderately high to highly toxic based on a hazard assessment when determining if a chemical can be listed for chronic effects pursuant to EPCRA section 313(d)(2)(B)," it stated.

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