January 2019

We wish all our clients and associates a very happy and prosperous 2019.

Some important regulatory deadlines for 2019 applicable to most manufacturing facilities:

REQUIREMENT DUE DATE
OSHA Injury and Illness Log Summary (OSHA 300A). Facilities must post Form 300A for calendar year 2018 February 1, 21019
Community Right to Know Survey March 1, 2019
OSHA Injury Tracking Application (ITA). Facilities with more than 10 employees must electronically submit data from the 2018 OSHA 300A form March 2, 2019
Hazardous Waste Biennial Report Not required this year
Annual Batch Reports April 1, 2019
Air Emission Statement May 15, 2019
Toxic Release Inventory (TRI) July 1, 2019
New Jersey Release and Pollution Prevention Report July 1, 2019

Some important new developments in the New Jersey Site Remediation Program:

    1. Capping of Volatile Contaminants for the Impact to GW Pathway Guidance now available (August 30, 2018)

The New Jersey Department of Environmental Protection announced the availability of the Capping of Volatile Contaminants for the Impact to Ground Water Pathway Guidance (August 2018). This guidance details the conditions and requirements under which capping may be allowed on a site-specific basis. Previously, capping of inorganic and semi-volatile organic contaminants were permitted under certain circumstances, but this did not include VOCs, such as benzene, toluene, TCE and PCE.

  1. Public Notification Requirements are updated (December 21, 2018)

The major change requires public notification within 14 days prior to commencing initial field activities associated with the remedial investigation (previously remedial action). For cases that initiated the remedial investigation prior to August 6, 2018 but have not yet satisfied the public notification requirements, the 14-day public notification is now due. However, for these cases, the Department is allowing the person responsible for conducting the remediation to comply with the public notification rule requirements by June 30, 2019.

  1. Ecological Evaluation Technical Guidance has been updated (August 6, 2018)

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