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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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  • What records must a subcontractor keep?

    Answer: If the certified renovator assigned to the project is assigned by the subcontractor, the certified renovator is responsible for preparing the records demonstrating that the renovation was conducted in compliance with the work practice standards, including training provided to non-certified workers. All renovation firms involved in a project share…

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  • I hear new record keeping requirements will take effect soon. What are they and when must my firm begin to comply with them?

    Answer: Beginning July 6, 2010, when the final invoice for the renovation is delivered, or within 30 days of the completion of the renovation, whichever is earlier, the renovation firm must provide information demonstrating compliance with the training and work practice requirements of the RRP Rule to the owner of…

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  • Are written follow-up notifications required after the initial telephone notifications?

    When a facility releases a reportable quantity of a hazardous substance, are there any requirements for written follow-up notification, after the initial telephone notifications, under the Emergency Planning and Community Right-to-Know Act (EPCRA) or the Comprehensive Emergency Response, Compensation, and Liability Act (CERCLA)? Under EPCRA, an owner or operator must…

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