The administrative stay for hydrogen sulfide (H2S) under EPCRA §313 was lifted in November 2011; therefore, facilities will be required to submit TRI reports for Reporting Year 2012 by July 1, 2013. Will there be any special applicability issues for the reporting of hydrogen sulfide?
The reporting requirements for hydrogen sulfide have not changed from those that have been in place since it was originally listed in 1993. Therefore, facilities should consider the following information in determining applicability:
Hydrogen sulfide is not a persistent bioaccumulative toxic (PBT) chemical. Therefore, it is subject to the standard activity thresholds of 25,000 pounds for manufacturing and processing and 10,000 pounds for otherwise use.
Hydrogen sulfide is listed without a chemical qualifier; therefore, it is subject to reporting in all forms in which it is manufactured, processed, or otherwise used.
For purposes of the de minimis exemption, the 1.0% level applies to hydrogen sulfide because it does not meet the Occupational Safety and Health Administration’s definition of a carcinogen. Therefore, hydrogen sulfide is exempt in a mixture at a concentration lower than 1.0%.
Additional information about the reporting of hydrogen sulfide and the lifting of the administrative stay are available at the following URL: