Right To Know 2019: 3 Mistakes To Avoid When Filing
When is the annual NYC Community Right-to-Know filing deadline? March 1st. Here are three mistakes you should and can avoid with your 2019 Right-to-Know filing:
There’s no question you have more than enough on your plate. But waiting till the last minute to submit your annual Right-to-Know filing only opens the door to all manner of potential disasters, some with costly ramifications.
You could be fined if you miss the deadline! And you can’t afford to make mistakes because you could be fined for that too.
Walden can help you gather all the information you need to prepare your Right-to-Know filing.
2. Assuming the NYC Community Right-to-Know filing doesn’t apply to you.
Even if you are “non-accountable,” you have to notify the Department of Environmental Protection in writing and be officially approved.
However, a wide variety of businesses and public agencies use potentially hazardous chemicals. If your operation falls into one of the following categories, the Right-to-Know program is aimed at you. You’ll have to report any chemicals you processed, stored, handled or used at any time during 2018, as long as the quantity was equal to or higher than the designated threshold reporting quantity (TRQ) for that chemical.
- Automotive businesses – body shops and service stations, etc. – must report all regulated substances.
- Drycleaners must report perchloroethylene (DF2000) and spot remover.
- Funeral homes must report anything flammable or known to be carcinogenic.
- Industrial or commercial businesses and utilities must report dielectric fluids contained in transformers, capacitors, etc. That could be mineral oil or spirits, PCBs, or tetrachloroethylene.
- Hotels, nursing homes, hospitals and commercial buildings must report paints, solvents and cleaning products.
- Material supply stores that sell products in non-consumer packaging must report listed substances.
3. Forgetting to include all the components.
Your filing must include all these items:
- Facility Inventory Form (FIF).
- Material Safety Data Sheet (MSDS) for every reported substance, whether pure or an ingredient in a mixture.
- Mixture Component Sheets, if appropriate.
- Submission Authorization Letter, signed by your officially designated representative.
- Fee invoice form.
- Your payment. Even if you’re filing online, you must send in your check right away. Otherwise you’ll run the risk of being out of compliance.