EPCRA rules apply to all types of sites, and are not limited to a particular industrial sector – reporting sites can be commercial, institutional, warehousing, retail or any other type of site which could store or use chemicals. Facilities with chemicals in quantities that equal or exceed the thresholds must report. The thresholds can be specific to different types of chemicals and can be as low as 500 pounds for some materials, and as high as 10,000 pounds.
In summary, to comply with hazardous chemical storage reporting requirements, for any hazardous chemical used or stored on-site above threshold amounts, facilities must maintain a material safety data sheet (MSDS), and submit the MSDSs to their State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC) and local fire department. Facilities must also report an annual inventory of these chemicals by March 1 of each year to their SERC, LEPC and local fire department.
Hazardous chemicals are any substances for which a facility must maintain a Material Safety Data Sheet (MSDS) under the OSHA Hazard Communication Standard – if a material has an MSDS, it is considered to be a hazardous chemical under EPCRA. This can include materials which might not immediately be considered “chemicals”, such as batteries, fuels, metals, etc.
Facilities that need to submit MSDSs or chemical lists under Section 311, also need to submit an annual inventory report for the same chemicals under EPCRA Section 312. This inventory report must be submitted to the SERC, LEPC and local fire department by March 1 of each year. Facilities provide either a Tier I or Tier II form. However, most States require the Tier II form be used.
Caltha LLP provides expert environmental consultant services in Iowa to prepare chemical storage inventory tracking systems, prepare and submit Tier II reports, and to develop cost effective compliance programs.
For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website
