Emergency Planning & Community Right to Know Act Tier II Reporting
Why is it important to comply with EPCRA?
Important provisions of EPCRA
Emergency Planning and Emergency Release Notification: Local governments, with the oversight and guidance from state governments, are required to prepare a chemical emergency response plan and review it annually. The chemical emergency response plan specifies actions to be taken in the event of an emergency release. Facilities must immediately notify first responders and various government agencies in the event of an emergency release.
Hazardous Chemical Storage Reporting Requirements: Industrial sites must meet a number of reporting and recordkeeping requirements under EPCRA. Sites that maintain Extremely Hazardous Substances (EHS) on-site over threshold values must work with local governments as they create their chemical emergency response plan. Facilities that maintain hazardous chemicals in excess of threshold values must submit the Safety Data Sheet (SDS) to the fire department and other state and local officials. Regulated sites with chemicals over the Tier II reporting thresholds must also annually report inventories of all on-site chemicals required to have a SDS (called Tier II Reporting). This information is in turn available to the public, subject to certain trade secret restrictions.
Toxic Chemical Release Inventory: EPCRA also requires facilities to annually submit a Toxic Release Inventory (TRI). TRI reporting (also known as “Form R”) is required for over 600
hazardous chemicals if they are used or stored on-site over specific threshold quantities.
Importance of implementing an active regulatory watch on EPCRA updates
modify threshold values, and add new data elements for reporting. Facilities should also monitor their chemical inventories to determine whether they exceed specific threshold values. This is particularly important where new hazardous substances are introduced to the facility.