Reminder: March 1 EPCRA Section 312 Reporting

February 4, 2019

It is once again time for ILMA members’ covered facilities to prepare and submit either Tier I or Tier II emergency and hazardous chemical inventory forms to the appropriate Local Emergency Planning Committee (LEPC), State Emergency Response Commission (SERC), and the fire department with jurisdiction over the particular facility. Most state and local agencies typically require the Tier II form. Be sure to submit the required form before March 1, as EPA can seek up to $37,500 per day per violation, even for violations of reporting requirements.

The Tier I/Tier II reporting is mandated under Section 312 of the federal Emergency Planning and Community Right-to-Know Act. At each covered facility, the submitted form must provide information for each hazardous chemical present at the facility on any one day over the past year in excess of 10,000 pounds for hazardous chemicals and 500 pounds for extremely hazardous chemicals.

“The Tier I/Tier II reporting should be routine for most ILMA members, as the Section 312 requirement has been in place for over 30 years,” said ILMA CEO Holly Alfano. “However, some members have missed the deadline, resulting in enforcement actions with penalties.”

If you have any questions about form requirements, check with your LEPC and SERC to ensure compliance.