Stephanie Salmon, Artemis Strategies; Jeff Hannapel & Christian Richter, The Policy Group, Washington, D.C. WASHINGTON ALERT CDR Reporting Deadline Approaching
REPORTING FOR THE RULE, PROMULGATED IN AUGUST 2011, BEGAN LAST FEBRUARY. Te reporting period for the
U.S. Environmental Agency (EPA) Chemical Data Reporting (CDR) Rule will end on June 30. EPA promulgated the rule on Aug.
16, 2011. It requires manufacturers of certain “chemical products” to report information related to production of these products every four years. Te CDR rule is an update to an earlier regulation known as the Inventory Update Reporting Rule, which was originally promulgated in 1986 under the T
Facilities that recycle, reprocess, reclaim or
reuse byproducts may be subject to the
reporting requirments. oxic Substances Control Act. Te
reporting period for calendar year 2011 began on Feb. 1.
Beginning in 2006, EPA required
manufacturers to report the produc- tion of inorganic materials (such as metals), with limited requirements to report byproducts. With the CDR rule, EPA expanded the requirements for reporting certain recycled byprod- ucts and issued additional guidance to help manufacturers identify the
ON THE HILL
Obama Establishes Trade Enforcement Group
President Obama signed an executive order on Feb. 28 establishing an Interagency Trade Enforcement Center within the Office of the U.S. Trade Representative.
The White House said the center will work to enforce U.S. trade rights as established under international trade agreements and domestic trade law. The center will provide the administration with more power to combat unfair trade practices. The center will employ members of the departments of Agriculture, Justice, Homeland Security, Com- merce, State and Treasury, as well as U.S. Intelligence Agencies. In his budget submitted to Con- gress, Obama proposed $26 million to fund the center.
Water Pipe Replacement Could Reach $1.7 Trillion Water pipe replacement costs could reach $1.7 trillion from now through 2050, ac- cording to “Buried No Longer: Confronting America’s Water Infrastructure Challenge,” a report by the American Water Works Association (AWWA). In its report, AWWA analyzed life expectancy of water main pipes, timing of the installation and replacement costs, among other things. According to the report, more than 1 million miles of pipe are nearing the end of their life. Plus, systems need to be expanded to serve growing populations. AWWA has determined that across the na- tion, the need for replacement and expansion are about equal. The replacement comes at an increasing burden to communities and residents’ water bills, which will reflect most of the replacement costs. The report indicated current costs for water pipe maintenance and re- placement are $13 billion each year. That number will contribute to the estimated $1 trillion of water pipe replacement costs expected from 2011 through 2035.
types of byproducts and recycling activities that may require reporting under the rule. Te CDR may not impact all met-
alcasting facilities. Companies should review generated byproducts and ap- plicable regulatory criteria to deter- mine if reportable chemical substances are “manufactured” and subject to the rule. Facilities that recycle, reprocess, reclaim or reuse byproducts (or send the materials offsite for reuse) may be subject to the reporting requirements.
Under the rule, reporting thresh-
olds for individual manufacturing sites are based on 2011 total annual sales (at the corporate level). If total annual sales are below $4 million, no reporting is required. If total annual sales are equal to or greater than $4 million but less than $40 million, data must be reported if site-specific chemical products equal or exceed 100,000 lbs. If total annual sales are greater than $40 million, the report- ing threshold is 25,000 lbs. Te information must be submit- ted via electronic reporting through utilization of EPA’s Central Data Exchange. Manufacturers must report again in 2016 if reportable chemical substances are manufactured above production thresholds in any of the preceding years. Metalcasting facilities are encour-
aged to review existing information on the CDR rule as provided on EPA’s website,
www.epa.gov/cdr.
Water pipe infrastructure replacement will cost $1 trillion through 2035. April 2012 MODERN CASTING | 15
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