More Data to Be Required on EPCRA Forms

EPA proposed adding parent company information and e-mail addresses to the Emergency and Hazardous Chemical Inventory Forms (Tier I and Tier II) under Section 312 of the Emergency Planning and Community Right-to-Know Act.

The Environmental Protection Agency has proposed increasing the information that must be listed on Emergency Planning and Community Right-to-Know Act (EPCRA) forms by facilities with certain amounts of extremely hazardous substances. EPCRA is a law enacted to encourage state and local emergency planning for releases and to give the public, emergency responders, and local governments information about hazardous and toxic chemical risks in their communities.

EPA's proposal was published Aug. 8; comments are due by Oct. 7 (Docket ID No. EPA-HQ-SFUND-2010-0763,

Current Tier I and II forms are available at

EPCRA's emergency planning provisions (40 CFR part 355) require covered facilities to provide a one-time notification to the State Emergency Response Commission (SERC) and the local emergency planning committee (LEPC). The list of extremely hazardous substances and threshold planning quantities that trigger the notification requirement is found in Appendices A and B of 40 CFR part 355.

"LEPCs informed EPA that some facilities have sites in remote locations and do not have operators present at all times. Thus, if there is a need to contact someone in an emergency, emergency response officials and State and local agencies need the contact information of the facility's parent company or the owner or operator of the facility. Therefore, under the facility identification section, EPA is also proposing to require facilities to provide information on the facility's parent company and the owner or operator of the facility, such as name, address and phone number, as well as the Dun and Bradstreet number of the facility's parent company. EPA is also proposing that the facility owner or operator provide their e-mail address," the proposal states.

The reporting requirement for extremely hazardous substances under section 312 is to submit an inventory form annually by March 1 to the SERC, LEPC, and the local fire department if the substance is present at a facility at any one time in an amount equal to or greater than 500 pounds or the threshold planning quantity (whichever is lower). Because the notification under section 302(c) is a one-time notification that occurred in 1987 for most facilities, and section 303(a) requires LEPCs to update their emergency plans annually, "it would be useful for LEPCs to get an update from facilities clarifying whether they are still subject to emergency planning. This will help ensure that local emergency plans are up-to-date and include all appropriate facilities," EPA said. "To better account for facilities subject to emergency planning and for LEPCs to use this information to improve the emergency response plans in their community, LEPCs requested that EPA require facilities to report if they are subject to emergency planning notification under EPCRA section 302. As a result, the Agency is proposing to add a new data element to indicate if facilities are subject to the emergency planning notification under EPCRA section 302."

EPA also proposed adding facility identification numbers for those facilities subject to the Chemical Accident Prevention under section 112 (r) of the Clean Air Act -- also known as the Risk Management Program or the Toxic Release Inventory (TRI) Program under section 313 of EPCRA.

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