January 2010
Chemical Inventory Reporting

Emergency Planning and Community Right-to-Know Act (EPCRA)

Do you own any bulk tanks at a customer site? An owner of bulk installations at a customer site has a duty under EPA regulations (Section 312) to notify the customer of their obligation to file Tier Form reports for each hazardous chemical that meets or exceeds the threshold planning quantities. The reminder must be mailed to an appropriate customer representative by February 15, 2010. The supplier must document its efforts to notify its customers of these requirements.

If the customer owns the bulk unit, then you are not required to remind or notify them on their reporting obligations.

Hospitals are exempted from the notification and reporting obligations. (Section 311(e)(4) of EPCRA and 40 CFR 370.2 and 355.20 of the regulations exclude from the definition of "hazardous chemical" any substance to the extent it is used in a research laboratory or a hospital or other medical facility under the direct supervision of a technically qualified individual.)

SARA Title III Reporting

March 1 is the filing deadline for your Hazardous Chemical Inventory Report. This report usually is submitted on a Tier I or Tier II Form. Keep in mind that your state may require one of these forms be used over the other or even have its own special form. Your state may even have different reporting quantities. Check with your State Emergency Response Commission (SERC) if you have questions regarding what form to use or other possible state requirements.

Please use the following website to check on your state reporting requirements, to download the Tier2 Submit 2009 software, and the Facility Submission Guide:

http://www.epa.gov/emergencies/content/epcra/tier2.htm

If you submitted this report last year, use it as a guide. The report(s) must be submitted to your Local Emergency Planning Committee (LEPC), your SERC and the local fire department with jurisdiction over the facility. Use the above website to see how each state wants to receive their reports and get information on the SERC and LEPC.

You can also use this website to search for information on your LEPC:

http://yosemite.epa.gov/oswer/lepcdb.nsf/HomePage?openForm

The EPCRA hotline for free help is 800-424-9346 or you can email them by going to this website: http://www.epa.gov/emergencies/contact_us.htm

Here is the EPCRA Frequent Questions website:

http://www.epa.gov/emergencies/content/epcra/epcra-qa.htm

Additional information related to SARA Title III can be found in the GAWDA EPA Reference Manual in sections 5, 6, 7, 8, and 10. (Remember, the GAWDA Reference Manuals are available to all members as a part of their membership.)

Feel free to contact me if you have any questions.

Michael Dodd

GAWDA DOT, Security, OSHA, and EPA Consultant
MLD Safety Associates, LLCP.O. Box 93
Poplar Bluff, MO 63902
(573) 785-5111
Fax: (573) 785-5112
Email: MLDSafety@hotmail.com

• Important:

  This information is offered by the Gases and Welding Distributors Association and your local distributor as general guidance only and may not explain all relevant safety precautions or hazards.