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

Challenges

Numerous notification and reporting requirements originate from the EPCRA and the Superfund Amendments and Reauthorization Act (SARA) of 1986. Some notification requirements apply in the event of a release of a hazardous substance, while other more routine notifications and annual reporting requirements are triggered by exceeding inventory or release limits. TRC assisted a large complex national manufacturing company with over 60 facilities identify whether each of their facilities were subject to specific EPCRA reporting requirements and how to achieve and manage the applicable compliance requirements.

Solutions

TRC developed a proprietary spreadsheet tool for use in compiling information from Safety Data Sheets (SDS) and/or production information (e.g., chemicals that may be coincidentally manufactured), which includes available Chemical Abstract Service (CAS) numbers. The spreadsheet is equipped with various regulatory lists against which the unique chemical-specific CAS numbers are cross-referenced to facilitate identification of potentially applicable requirements.

For this national client, TRC tailored the spreadsheet tool to identify relevant requirements for the facility. Once regulated chemicals were identified, the spreadsheet could be populated with both the maximum onsite amount (inventory) and annual throughput of such chemicals for use in performing a threshold analysis.

This approach determined whether such amounts could trigger applicable notification and reporting threshold amounts. A critical review of contributing materials is also performed by experienced EPCRA compliance specialists to determine whether any exemptions could apply. Finally, TRC assisted in preparing the required notifications and reports. Output generated from the customized spreadsheet provided the required documentation supporting applicability and the basis for reporting. These results are routinely incorporated into back-up documents that TRC provides for the clients’ records.

Results

TRC was able to identify all EPCRA-related regulatory requirements for the client and assisted in providing detailed reports and necessary documentation to the applicable state and federal agencies to ensure compliance.

For over 25 years, TRC has revised the proprietary spreadsheets annually to facilitate an accurate threshold analyses and reporting requirements for numerous facilities across the U.S. This spreadsheet can also be used to identify chemicals subject to other regulatory requirements, such as chemical specific OSHA regulations, USEPA Risk Management Program and DHS Chemical Facility Anti-Terrorism Standards. This tool allows TRC to systematically and consistently (year-over-year) provide a means to assess and support applicability analyses and report preparations.