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Oklahoma State University

EMC- EPCRA Reporting Compliance

Date Location Price Register Now
TBA Frisco, TX $300  

This seminar is a hands-on experience with two Federal reporting requirements established under the Emergency Planning and Community Right-To-Know Act (EPCRA). Compliance with section 311 and 312 mandates facilities that exceed quantity in storage of certain chemicals, including any material for which a SDS is received and stored in 10,000 pounds or more, must be reported on Emergency and Hazardous Chemical Inventory Forms (Tier Two’s). This seminar goes into detail of determining what gets reported and how to accomplish the reporting. Similarly, section 313 mandates facilities that manufacture, process, or use more than prescribed amounts must complete a Toxic Release Inventory (TRI or Form R) for each compound handled above threshold amounts.

Who must comply with EPCRA Section 311 & 312 and submit a Tier II form?

Any facility required under Occupational Safety and Health Administration (OSHA) regulations to maintain MSDSs for hazardous chemicals stored or used in the work place. Facilities with chemicals in quantities that equal or exceed the following thresholds must report:

  • For Extremely Hazardous Substances either 500 pounds or the Threshold Planning Quantity (TPQ), whichever is lower.
  • For gasoline (all grades combined) at a retail gas station, the threshold level is 75,000 gallons (or approximately 283,900 liters), if the tank(s) was stored entirely underground and was in compliance at all times during the preceding calendar year with all applicable Underground Storage Tank (UST) requirements at 40 CFR part 280 or requirements of the State UST program.
  • For diesel fuel (all grades combined) at a retail gas station, the threshold level is 100,000 gallons (or approximately 378,500 liters), if the tank(s) was stored entirely underground and the tank(s) was in compliance at all times during the preceding calendar year with all applicable UST requirements at 40 CFR part 280 or requirements of the State UST program.
  • For all other hazardous chemicals: 10,000 pounds.

Who must comply with EPCRA Section 313 and submit a Toxic Release Inventory (TRI)?

Your facility is required to report to the TRI Program if it meets ALL of these three threshold criteria:

  • The facility is included in a TRI-covered North American Industry Classification System (NAICS) code.
  • The facility has 10 or more full-time employee equivalents
  • The facility manufactures (defined to include importing), processes or otherwise uses any EPCRA Section 313 chemical in quantities greater than the established threshold in the course of a calendar year.

What are the penalties for non-compliance with EPCRA?

EPCRA section 325 allows civil and administrative penalties ranging up to $10,000 - $75,000 per violation or per day per violation when facilities fail to comply with the reporting requirements. Criminal penalties up to $50,000 or five years in prison apply to any person who knowingly and willfully fails to provide emergency release notification.