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  • Why does EPA recommend submitting a list for EPCRA 311?

    Why does EPA recommend submitting a list rather than Material Safety Data Sheets (MSDS) to meet the requirements of Section 311? Lists will minimize the paperwork burden for state and local governments and local fire departments. In addition, the list can be used as an index to inventory forms required…

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  • Facilities that close during a reporting year

    A facility storing hazardous chemicals on site permanently ceases operations and notifies the State Emergency Response Commission (SERC). Since the facility will no longer be in operation on March 1 of the following year, must the owner/operator of the closed facility submit a Tier I or Tier II hazardous chemical…

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  • Recommended approach for reporting lead acid batteries when complying with Tier II reporting

    Does EPA have a standard or recommended reporting approach for lead acid batteries when complying with EPCRA Section 312 Chemical Inventory Reporting (i.e., Tier II reporting)? EPA suggests that facilities report for lead acid batteries in the same manner they used when complying with EPCRA Section 311 MSDS reporting requirements…

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  • Purchases but never receives or stores a hazardous chemical over threshold amount

    If a facility purchases more than 10,000 pounds of a hazardous chemical for which OSHA requires an MSDS in a calendar year but never actually receives or stores more than the 10,000 pound threshold at one time, must the facility report under EPCRA Sections 311 and 312? The MSDS and…

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  • How are mixtures handled for Sections 311 and 312 reporting?

    The owner or operator of a facility may meet the requirements of Sections 311 and 312 by choosing one of two options: • Providing the required information on each component that is a hazardous chemical within the mixture. In this case, the concentration of the hazardous chemical in weight percent…

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  • EPCRA 312 Back Reporting for Previous Years

    Facilities subject to EPCRA section 312 (40 CFR part 370) must submit an inventory form annually to the state emergency response commission (SERC), local emergency planning committee (LEPC), and local fire department. Do facilities have to report for previous years if they were subject to hazardous chemical inventory reporting but…

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  • EPCRA 311 / 312 Applicability to Brine / Salt Solutions

    Are facilities required to prepare or have available a material safety data sheet/safety data sheet (MSDS/SDS) for brine/salt solutions under the Occupational Safety and Health Administration (OSHA) Hazard Communication Standard (HCS) ( 29 CFR 1910.1200 )? Yes, facilities are required to prepare or have available an MSDS/SDS for brine/salt solutions…

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  • Definition of Ambient Temperature for EPCRA 312 Reporting

    The Tier II Hazardous Chemical Inventory form, used to meet annual EPCRA section 312 reporting requirements, requires facility owners or operators to note whether reported hazardous chemicals are present at, above, or below ambient temperature. What is meant by ambient temperature? Ambient temperature means that the material is stored in…

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  • Electronic Submission of Tier II Inventory Information

    Pursuant to the Emergency Planning and Community Act (EPCRA) Section 312, facilities must submit by March 1st every year Tier II inventory information regarding any hazardous chemical present at their facility at any time during the previous calendar year in an amount equal to or in excess of its threshold…

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  • Does Ammonia in Ammonium Hydroxide count toward the EHS threshold for reporting under EPCRA section 312?

    A facility has 9,000 pounds of ammonium hydroxide (19 percent solution) present on site at a given time. For reporting under the Emergency Planning and Community Right-to-Know Act (EPCRA) section 312, must the amount of ammonia in ammonium hydroxide be counted (and aggregated) towards the reporting threshold for extremely hazardous…

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  • Are renovations performed on detached garages, sheds and other detached outbuildings on the property subject to the RRP Rule?

    Yes. EPA interprets target housing to include pre-1978 buildings or structures that are (1) located on the residential portion of the property, and (2) associated with the residential use of the property. As a practical matter, the entire property of most urban and suburban residential lots is normally considered to…

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  • How do the RRP requirements apply to renovations on a pre-1978 building that contains both multi-room apartments (i.e., target housing) and zero-bedroom dwellings?

    In pre-1978 buildings that contain a mix of target housing and zero-bedroom dwellings, the Lead Renovation, Repair, and Painting (RRP) Rule applies only to renovations performed in target housing and common areas. Common areas are those portions of a property generally accessible to residents/users of target housing, and can exist…

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  • Does zoning affect the target housing determination? For example, would a pre-1978 house that is zoned for commercial or office use, but used for residential purposes be considered target housing?

    In determining whether a pre-1978 property is target housing, it is the actual or intended use of the property that matters, not its zoning classification. Therefore, a pre-1978 house that is used or intended to be used as a residence, even if only temporary, is target housing regardless of its…

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  • Use Federal Tier II Form When Claiming Trade Secret

    40 CFR Part 350 allows facilities to withhold certain chemical information when reporting under EPCRA if the facility claims those chemicals to be a trade secret. When submitting the required trade secret claim package for Tier II reports, must a facility use the federal Tier II inventory form or can…

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  • Ethanol added to food / beverages and Tier II reporting (i.e., EPCRA Section 312)

    Is Ethanol (CAS# 64-17-5) that is added to foods or alcoholic beverages exempt from the Emergency Planning and Community Right-to-Know Act (EPCRA) section 312 chemical inventory (i.e., Tier I/II) reporting requirements? EPCRA Section 312 requires facility owners or operators to submit annual chemical inventory reports (Tier I/Tier II Forms) for…

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