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No Supplier Notification Requirements for Tier II Chemical Inventory Reporting
Under EPCRA Section 313, suppliers are required to notify customers that their mixtures or trade name products contain a TRI chemical. Are there similar supplier notification requirements for Tier II chemical inventory reporting under EPCRA Section 312? There is no supplier notification requirement for Tier II chemical inventory reporting. However…
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Definition of "environment"
How is the term "environment" defined? CERCLA section 101(8) defines "environment" as "(A) the navigable waters, the waters of the contiguous zone, and the ocean waters of which the natural resources are under the exclusive management authority of the United States under the Fishery Conservation and Management Act of 1976…
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Choosing the chemical name to list on the List of Hazardous Substances
How does EPA choose the chemical name(s) to list for each substance on the List of Hazardous Substances at Table 302.4 of 40 CFR 302.4? A single chemical may often be known by several different names. To avoid confusion, the Agency has limited the chemical names listed in 40 CFR…
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What items are covered by the term "rolling stock"?
The definition of "facility" under EPCRA Section 329 states that "(f)or purposes of Section 304, term [i.e., facility] includes motor vehicles, rolling stock, and aircraft." The term "rolling stock" is not defined further. For purposes of EPCRA Section 304, what items are covered by the term "rolling stock"? The term…
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Person in charge for CERCLA release reporting
How does one determine who is the person in charge? Determining who is the person in charge depends on a number of variables, including the specific operation involved, the management structure, and other case-specific considerations. EPA believes that it is unnecessary and impractical for the government to determine the person…
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Differences between the risk management program and EPCRA
How do the Clean Air Act (CAA) risk management program requirements differ from the hazardous chemical reporting requirements under the Emergency Planning and Community Right-to-Know Act (EPCRA)? The hazardous chemical reporting requirements under EPCRA sections 311 and 312 ( 40 CFR Part 370 ) are separate and distinct from those…
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