By Mary Ellen Ternes
The EPA has listed its 1994 Administrative Stay of the hydrogen sulfide (H2S) reporting requirements pursuant to the Emergency Planning and Community Right to Know (EPCRA) Section 313 Toxic Release Inventory (TRI) regulations. See 76 Fed. Reg. 64022 (Oct. 17, 2011). Hydrogen Sulfide was added to the agency’s EPCRA Section 313 list of toxic chemicals on December 1, 1993. However, on August 22, 1994, the EPA issued an administrative stay in order to evaluate human health effects and exposure analysis issues. 59 Fed. Reg. 43048. The EPA has completed its evaluation, including comments received in response to EPA’s February 26, 2010, notice of “Intent to Consider Lifting Administrative Stay.” 75 Fed. Reg. 8889. Specifically, the EPA has determined that hydrogen sulfide causes chronic health effects in laboratory animals at concentrations as low as 20 parts per million, and due to its toxicity, significant adverse effects in aquatic organisms. With the lifting of this stay, facilities releasing hydrogen sulfide and otherwise subject to the EPCRA reporting requirements will need to include releases of hydrogen sulfide for the first time in their July 1, 2013, reports for the reporting year 2012.