EPCRA Reporting Requirements

Did you know that the deadline for annual EPCRA reporting is right around the corner? By March 1st, you must submit your report for the previous calendar year. Use our list of FAQs below to better understand EPCRA reporting requirements.

EPCRA Reporting Requirements

Is my facility covered?

If your facility must maintain material safety data sheets (MSDSs) or safety data sheets (SDSs), it is covered. In addition, all facilities that house the following quantities of hazardous chemicals must report:

• 500 pounds or more of Extremely Hazardous Substances (EHSs), or the Threshold Planning Quantity (TPQ) if it is lower
• 75,000 gallons or more of gasoline at a retail gas station if the tank(s) was stored entirely underground and was in compliance at all times of the preceding calendar year with applicable Underground Storage Tank (UST) requirements
• 100,000 gallons or more of diesel fuel at a retail gas station if the tank(s) was stored entirely underground and was in compliance at all times of the preceding calendar year with applicable UST requirements
• 10,000 pounds of any other other hazardous chemical

Please note that state requirements may be more stringent than federal requirements.

What constitutes a hazardous chemical?

To learn whether a substance is classified as a hazardous chemical, review the criteria listed in the OSHA Communication Standard. All facilities with hazardous substances must maintain an MSDS (or SDS), a detailed information sheet that supplies data regarding health hazards and physical hazards of chemicals as well as protective measures that can be used to evade these hazards. Over 500,000 products have MSDSs (or SDSs). Typically chemical manufacturers will provide MSDSs (or SDSs) to customers.

What does reporting entail?

• Facilities must submit MSDSs (or SDSs) of on-site hazardous chemicals at or above the reporting threshold to their State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC), and local fire department. If you prefer, you may submit a list of hazardous chemicals grouped into categories instead. After becoming subject to EPCRA regulations, new facilities have three months to submit these reports, and it is a one-time submittal.
• Each year, facilities must also submit an annual inventory report of the same chemicals to their SERC, LEPC, and local fire department by March 1st.

How do I submit a report?

You will submit either a Tier I or Tier II form depending on your state’s requirements. Most states require the Tier II form, which requires the following information:

• Basic facility identification information
• Employee contact information (emergency and non-emergency)
• Information about chemicals stored/used at the facility:
  • Chemical name or common name (as indicated on the MSDS/SDS)
  • Estimate of maximum amount of chemical present at facility at any time during the preceding year
  • Estimate average daily amount of chemical present at facility during the preceding year
  • Brief description of how the chemical is stored
  • Location of chemical at the facility
  • Indication of whether the facility owner wishes to withhold location information from public disclosure

Do you need help understanding EPCRA reporting requirements? Would you like assistance preparing your reports? As a reminder, they are due on March 1st, and Environmental Works is here to help you every step of the way. With our experience and expertise in regulatory compliance as well as our well-established relationships with regulatory agencies, we are confident that we can help you achieve and maintain compliance with EPCRA. To learn more, please contact us today.