What you need to know about the EPA’s Emergency Planning and Community Right to Know (EPCRA) Reporting Requirements
What you need to know about the EPA’s Emergency Planning and Community Right to Know (EPCRA) Reporting Requirements
The Emergency Planning and Community Right-to-Know Act (EPCRA) of 1986 was created to help communities plan for emergencies involving hazardous substances. EPCRA requires hazardous chemical emergency planning by federal, state and local governments, Indian tribes, and industry.
One of the major sections of the law that pertains to reporting is Section 313, which regulates toxic release inventory (TRI) reporting and is commonly known as Form R. This section requires certain facilities to submit an annual report on the amount of toxic chemicals released into the environment (routinely or accidentally), and requires manufacturers to report releases of more than 600 toxic chemicals to the environment.
A plant, factory, or other facility is subject to Section 313 if it meets all of the following:
- It is included in a covered SIC Code;
- It has 10 or more full-time employees (or the equivalent 20,000 hours per year); and
- It manufactures, imports, processes, or otherwise uses any toxic chemical listed in amounts greater than “threshold quantities.”
- Or, it is a federal facility, regardless of its SIC classification.
Threshold Quantities as defined under the program are as follows:
- If a facility manufactures or processes any listed toxic chemicals, the threshold quantity will be 25,000 lb per toxic chemical or category.
- If a facility otherwise uses any listed toxic chemicals (without incorporating it into any product or producing it at the facility), the threshold quantity is 10,000 lb per toxic chemical or category.
Facilities must report the required information for each listed toxic chemical manufactured, imported, processed, or otherwise used at the facility exceeding the annual threshold. Reports are due to the EPA by July 1st each year, and non-reporters are subject to penalties of $27,500 per day. It should be noted that EPCRA does not put limits on which chemicals can be used, stored, or disposed of; it merely requires a facility to report such information to the EPA and the surrounding community.
More information on EPCRA can be found at http://www2.epa.gov/epcra. C.T. Male Associates’ Environmental Services Division staff routinely assists our clients in maintaining compliance with a wide variety of federal and state-mandated reporting programs, including EPCRA. To speak with one of our staff Engineers knowledgeable in reporting practices, please contact James Young, Ph.D. at 518-786-7541.