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Environmental consulting

The filings, prepared
and ready to certify

Tier I and Tier II, TRI, and the state and federal waste summaries. Each one is arithmetic applied to a year of records, and each one has a hard date on it. We assemble them from your data and hand them over complete, so certifying is a review rather than a scramble.

The work

The filings
we prepare

Take one of them or all of them. They draw on the same underlying records, so doing them together costs less effort than doing them apart.

01

Tier I and Tier II chemical inventory

The annual inventory of what is held on site, prepared from your own chemical and waste data and ready for your authorized official to certify. Due the first of March, every year, and the date does not move.

02

TRI reporting and Form R

Releases, transfers and waste management quantities for listed chemicals, with the estimation basis behind every figure written down rather than reconstructed two years later by someone who was not there.

03

State annual waste summaries

The Texas Annual Waste Summary and its equivalents elsewhere, assembled from manifest and disposition data rather than rebuilt each February from paperwork held in three places.

04

RCRA biennial reporting

Every other year, covering the odd-numbered year before it, for large quantity generators and for facilities that treat, store or dispose. Easy to lose track of precisely because it is not annual.

Not the same thing

Environmental consulting
is not sustainability consulting

The two get used interchangeably and they are different disciplines, with different questions, different deliverables and often different people in the room.

Environmental consulting, here, is the regulatory reporting: Tier I and Tier II, TRI, and the state and federal waste summaries. It is about obligation. Did the filing go in, was it right, and can it be defended.

Sustainability consulting starts where compliance ends. What could this operation do beyond what it is required to do, what is that worth, and how is the result evidenced. The measure is whether the target was real and whether it moved.

KODA does both, and they are scoped separately, because an operation with a deadline to meet and an operation with a diversion target to hit need different work.

Looking for the other one?

Diversion targets, ESG and customer disclosure, zero-waste programs and the data behind them.

When operations call

What usually
prompts it

Almost never a general wish to improve. Nearly always one specific thing with a date on it.

01

A reporting deadline approaching with the data held in three places

02

An inspection finding on a filing that was late, short or inconsistent

03

A first year of reporting, where nobody has done it here before

04

A process or product change that may have crossed a threshold

05

An acquisition bringing sites whose filings nobody has mapped

06

The person who used to do it having left

What you get back

What you
get back

The useful test is whether the person who has to sign it can read it once and know it is right. A submission that needs explaining before it can be certified has not saved anyone anything.

These are the filings we are asked for most. If you carry one that is not listed here, it is still worth asking about.

  • Completed submissions ready for your official to certify
  • The supporting data in a form you can check line by line
  • The estimation basis recorded wherever a figure is estimated
  • Distribution handled where a filing goes to more than one recipient
  • A copy of everything filed, kept as the starting point for next year

Questions

Asked most often

Can you sign the filings for us?

No, and nobody can. The certifying official on a Tier II is the owner, operator or their authorized representative; on a Form R it is a senior management official of the facility. We prepare the submission complete and put it in front of that person, so certifying it is a review rather than an assembly job.

Can we use you for reporting without using you for the waste?

Yes. It is scoped and engaged on its own. Where KODA does handle the material the reporting is easier, because the manifest and disposition data is already held rather than gathered at the end of the year — but that is a convenience, not a condition.

We are not sure whether we have to file.

That is worth settling deliberately rather than carrying as an assumption, and the answer is sometimes no. It is a short conversation either way, and a better one in October than in February.

Start with the problem
that has a date on it

Tell us what is in front of you and we will tell you what it would take.