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  • Are manufacturers of household products exempt from reporting under 311 and 312?

    Is a facility that manufactures household products exempt from reporting under Sections 311 and 312 due to the household products exemption in Title III? Section 311(e) exempts from the definition of "hazardous chemical" any substance to the extent it is used for personal, family, or household purposes, or is present…

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  • Exemption for research laboratories and medical facilities under 311 and 312

    Are research laboratories and medical facilities exempt from reporting under Sections 311 and 312? Research laboratories and medical facilities are not exempt from reporting requirements under Sections 311 and 312, rather, Section 311(c)(4) of Title III excludes from the definition of hazardous chemical: "Any substance to the extent it is…

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  • Do facilities that submit lists have to file revised MSDSs?

    If a facility submits a list to comply with Section 311, does the facility have to supply a revised MSDS with significant new information or a new MSDS for substances that become present on-site after the initial reporting deadline and exceed the threshold within three months as required by Section…

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  • Filing trade secrecy claims internationally

    A chemical company has one operation in a foreign country and an identical operation in the U.S. For one chemical, they wish to file a trade secrecy claim under Sections 311 and 312. With regard to public disclosure, all non-government entities in the foreign country are bound by a confidentiality…

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  • TXT2, Regulated Identity, and Customer Numbers for Tier II reporting

    Where can a facility find their TXT2 Number, Regulated Entity Number, and Customer Number that may be needed to complete the EPCRA Section 312 Chemical Inventory Report (i.e., Tier II report)? TXT2 Numbers, Regulated Entity Numbers, and Customer Numbers are not federally designated or tracked. These number are designed by…

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  • Is the Section 311 requirement an annual or a one-time reporting requirement?

    Section 311 is a one-time reporting requirement unless there are any significant changes that affect the information that was already submitted.

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  • Are mobile boosters eligible for the transportation exemption?

    An oil company owns many wells on an oil field. Each well is on its own plot of land. These plots are not adjacent or contiguous and, therefore, each well is its own facility. When operating these wells, it is sometimes necessary to inject air or gas into the well…

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  • State acceptance of Tier2 Submit

    Does my state accept Tier2 Submit? To find out whether or not your state accepts Tier II submissions created by Tier2 Submit, review the information for your state on the State Tier II Reporting Requirements page .

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  • What is the 312 deadline if March 1 falls on a weekend?

    Under EPCRA §312, Tier II information for any calendar year must be submitted to the State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC), and local fire department by March 1st of the following year. What if the March 1st reporting deadline falls on a Saturday or Sunday? Tier…

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  • Applicability of EPCRA 311 Exemptions To Extremely Hazardous Substances

    The definition of a hazardous chemical under EPCRA Section 311 outlines exempted chemicals that are therefore not subject to material safety data sheet (MSDS) reporting or Tier II chemical inventory reporting. Do the exemptions from the definition of hazardous chemical also apply to extremely hazardous substances (EHSs)? EHSs are a…

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  • Waste streams and the mixture rule

    Where there are several waste streams with the same identification number, is it sufficient to know the average quantities, or the maximum observed quantity, of hazardous constituents of the waste streams in order to apply the mixture rule to all of them? No. The mixture rule provision applies only to…

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  • Responsibility of transportation owners or operators in the event of a release

    What is the responsibility of transportation owners or operators in the event of a spill or release of extremely hazardous substances or CERCLA hazardous substances? Although owners or operators of facilities in transportation or those that store substances under active shipping papers are not required to notify state and local…

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  • Providing Tier II Location Information for Chemicals In Multiple Area

    Pursuant to EPCRA Section 312, facilities must submit Tier II inventory information by March 1st every year. As part of this information, facilities must provide a brief description of the precise location of the chemical so that emergency responders can easily locate the area. How should facilities that have the…

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  • Can states designate liquified petroleum gas facilities under Section 302

    Does the statute allow the state to designate facilities which produce, use, or store certain quantities of liquified petroleum gas as emergency planning facilities? EPA considers the designation of additional facilities to be accomplished through naming individual sites or companies, or by designation of certain classes of facilities as newly…

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  • Pipeline tanks and the transportation exemption in Title III

    An oil corporation's pipeline facility contains three kinds of tanks. One type is a breakout tank used to receive and store hazardous liquids transported by a pipeline for reinjection and continued transportation by the corporation's pipeline. Another type is used to receive and store hazardous liquid for delivery to pipelines…

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