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  • What is a reactive and non-reactive solid EHS?

    Reactive solid means any extremely hazardous substance denoted with “a” in the “Notes” column in Appendix A or B of 40 CFR 355. Reactive solids are more likely than other solids to be dispersed into the air due to the energy or heat created from their reactivity with water or…

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  • How did states form their SERCs?

    How are States expected to form their State Emergency Response Commission (SERC) as required under Title III? States are required to establish a State Emergency Response Commission (SERC) under Title III. The SERC may consist of existing emergency response organizations or may be an entirely new mechanism to address this…

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  • Can I apply a product using a method that is not specified in the directions for use?

    List N: Disinfectants for Use Against SARS-CoV-2 View List N, a searchable and sortable list of products for use against SARS-CoV-2, the novel human coronavirus that causes COVID-19. Any time you use an EPA-registered disinfectant, you should read the product label and follow the directions, including the method of application…

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  • Pesticide applicator quantity applied to threshold or transportation exemption

    A farmer contracts with an applicator to spray pesticides on his fields. The applicator drives a tank truck onto the farmers' field and sprays the pesticide from the truck onto the fields. For purposes of Section 302 emergency planning requirements, are the EHSs in the truck considered present at the…

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  • State refusing to comply with the emergency planning provisions

    What will happen if a State refuses to comply with the emergency planning provisions? A governor who does not designate a State emergency response commission becomes the commission by default. While the governor could choose not to fulfill any of the Title III provisions, the public could still request information…

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  • Section 302 notification requirements and mixtures with unknown components

    Are facilities exempt from Section 302 notification requirements if they produce, use, or store mixtures whose extremely hazardous substance component information is not available on the MSDS provided by the manufacturer? If the facility which produces, uses, or stores mixtures knows or reasonably should know the components of the mixture…

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  • Do disinfectants kill newer variants of coronavirus?

    List N: Disinfectants for Use Against SARS-CoV-2 View List N, a searchable and sortable list of products for use against SARS-CoV-2, the novel human coronavirus that causes COVID-19. Yes, EPA expects all products on List N to kill all variants of SARS-CoV-2. Genetic changes to the virus do not impact…

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  • TPQ calculations for hazardous substances in molten form

    Facilities are subject to emergency planning and notification requirements under EPCRA (also known as SARA Title III) when an extremely hazardous substance (EHS) is present at a facility in an amount equal to or in excess of its TPQ. For some EHSs that are solids, two TPQs are given (e.g…

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  • Reporting responsibility under EPCRA §302 for a facility with several unrelated companies?

    A public warehouse is used by several unrelated companies to store extremely hazardous substances (EHSs). For purposes of emergency planning notification, who is responsible, under EPCRA Section 302, for notifying the State Emergency Response Commission if a threshold planning quantity (TPQ) of an EHS is present at the warehouse? The…

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  • Can states designate liquified petroleum gas facilities under Section 302

    Does the statute allow the state to designate facilities which produce, use, or store certain quantities of liquified petroleum gas as emergency planning facilities? EPA considers the designation of additional facilities to be accomplished through naming individual sites or companies, or by designation of certain classes of facilities as newly…

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  • Transportation exemption and EPCRA emergency planning

    To what extent is an LEPC/TEPC required to plan if there are only a few (or no) facilities having extremely hazardous substances present in excess of threshold planning quantities, but there is significant interstate transportation of these and other hazardous substances? While Section 327 of Title III generally exempts the…

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  • My firm drills a series of 1/2-inch diameter holes in sheet rock to dry it out where rooms have been flooded. Is drilling these holes a prohibited practice?

    No. The requirement for HEPA exhaust control does not apply to the use of all power tools. Specifically, HEPA exhaust control is not required when using a power drill to drill holes in sheetrock. When using a power drill with a drill bit to cut through sheetrock, the speed associated…

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  • Can disinfectant products be used on people?

    List N: Disinfectants for Use Against SARS-CoV-2 View List N, a searchable and sortable list of products for use against SARS-CoV-2, the novel human coronavirus that causes COVID-19. The products included in EPA's list of disinfectants for use against SARS-CoV-2 (COVID-19) are for use on surfaces, not humans. Please see…

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  • Why are disinfectants marketed and sold under different brand and product names?

    List N: Disinfectants for Use Against SARS-CoV-2 View List N, a searchable and sortable list of products for use against SARS-CoV-2, the novel human coronavirus that causes COVID-19. Companies that register disinfectant products can allow other companies to sell the product under their own product and company name. This is…

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  • Would pesticide sprayed on ground count towards §302 threshold?

    Section 302 requires owners and operators of facilities that have extremely hazardous substances (EHSs) present above the threshold planning quantity (TPQ) to participate in emergency planning ( 40 CFR §355.20 ). If a facility has a pesticide sprayed on its grounds without first being stored at the facility, must the…

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