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Emergency Planning and Community Right-to-Know

Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA) is also referred to as the Toxic Release Inventory or TRI. Under Section 313, facility owners and operators are required to publicly report releases of specifically listed chemicals to the land, air and water on an annual basis. There are currently over 600 chemicals and compounds on these lists. Facilities are also required to report transfers of toxic chemicals for waste management at off-site locations. Other sections of EPCRA (301-303, 304, 311 & 312) address emergency planning, community notification, and chemical storage requirements.

Who is required to report?

EPCRA reporting requirements apply to facilities that:

have 10 or more full-time employees.

are included in a covered SIC code group (10,12, 20-39, and some others).

have manufactured, processed or otherwise used a toxic chemical listed in
CFR Section 372.65 in excess of specified threshold quantities (typically
10,000 #/yr for "use" and 25,000 #/yr for "manufacturing" and "processing").

This mandatory reporting requires the submittal of data to both USEPA and the State environmental agency where the facility is located by June 30 for the preceding calendar year. Specific forms (paper or electronic) must be used for filing the data. Trade secret information can be protected if certain rigorous criteria are met.

How Omni Tech's experience with EPCRA Section
313 can help you

An experienced Omni Tech professional can help your facility staff:

determine if your facility is required to file annual information under EPCRA
Section 313 or other sections of EPCRA.
provide training and guidance on how to gather and compile the information
necessary for submittal in an effective manner (having a coordinated procedure for this activity can be of great value).
develop a computerized system for the collection and sorting of required
information in a manner that will make future data management less time consuming and more efficient. This system will minimize the need to do last minute data collection and analysis, resulting in fewer reporting errors and overtime hours. False or incorrect submittals can result in monetary penalties.
develop a clear and concise communications program for sharing this
information and its meaning with employees, neighbors and local officials. Since all data submitted under EPCRA becomes public information (including Internet postings), it is much easier to explain its meaning and relative risk in a proactive vs. reactive manner. That need is especially critical if any of the named chemicals or compounds have known human health impacts.

For information contact Jim Pollack at:
989-631-3377 ext. 233
E-mail: jpollack@omnitechintl.com
Fax 989-631-0812

or contact Omni Tech Headquarters



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