EPA Updates to EPCRA Section 312 (Tier I and II Reporting) Requirements

The US Environmental Protection Agency (EPA) has modified its Emergency Planning and Community Right-to-Know Act (EPCRA) Section 312 Emergency and Hazardous Chemical Inventory Forms (Tier I and Tier II forms) with both new mandatory and optional data elements and updates to the Tier II form structure.

The following data is now mandatory on Tier I and II forms:

  1. Reporting facility’s latitude and longitude

  2. Identification numbers assigned under EPA’s Toxic Release Inventory (Form R reporting) program and Risk Management Program (if applicable)

  3. Whether the facility is manned or unmanned and the maximum number of occupants present at any one time

  4. Whether the facility is subject to EPCRA Section 302 (Emergency Planning Notification) and the Clean Air Act Section 112 (r) (Risk Management Program)

  5. Contact information for the individual responsible for completing the forms and emergency coordinator for facilities subject to EPCRA Section 302

  6. Owner/Operator and emergency contact email addresses

In addition to the above, the rule also revised the range codes for the maximum and average daily amount of the hazardous chemical at the facility and added optional data elements for facility phone number and parent company contact information.

EPA also made revisions specific to the Tier II form:

  1. Added separate data fields for reporting pure chemicals and mixtures

  2. Facilities must provide a description for storage types and conditions rather than reporting codes

  3. Revisions to allow for reporting of additional state or local reporting requirements or to voluntarily report hazardous chemicals below the reporting thresholds

These changes are effective January 1, 2014 for reporting year 2013.  Forms for reporting year 2013 are due March 1, 2014.

Please contact Linda Swift at (508) 970-0033 extension 119 or via email at lswift@capaccio.com with any questions you may have regarding these changes.

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