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  • Gasoline and diesel fuel UST compliance determination

    Are State or Tribal Emergency Response Commissions (SERCs or TERCs), Local or Tribal Emergency Planning Committees (LEPCs or TEPCs), or fire departments required to determine if facilities are in compliance with underground storage tank (UST) requirements? No. SERCs/TERCs, LEPCs/TEPCs, and fire departments are not required to make the determination themselves…

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  • Generic 311/312 reporting for oil fields or wells

    A petroleum company owns many oil wells on a large oil field. Each well is on its own plot of land. These plots of land are not adjacent or contiguous and the oil field itself spans many local planning districts. For purposes of Sections 311/312 reporting, is each oil well…

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  • Oxygen used at a hospital by technically qualified individuals

    A hospital stores oxygen in a large outside bulk storage tank and delivers the material, as needed, throughout the hospital using a piping system (the oxygen is used only in the treatment of patients). The bulk storage tank is routinely maintained by hospital maintenance people but the oxygen itself is…

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  • Filing state trade secret provisions

    A chemical company in Louisiana filed their Section 311/312 reports by hazardous components. The Louisiana State Right-to-Know laws require companies to report on all unique substances present at the facility. For example, if chemical A and chemical B are blended to make mixture C, than the facility would have to…

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  • Ammonia sales at farm supply companies

    A farm supply company sells ammonia as a fertilizer to farmers. Is the ammonia, when held by the farm supplier, exempt from EPCRA Sections 311 and 312 reporting? EPCRA Section 311(e)(5) exempts "any substance to the extent it is used in routine agricultural operations or is a fertilizer held for…

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  • Public access for MSDSs

    Where should citizens go to request MSDSs on chemicals in a facility within their community? Each submitted MSDS or list along with the community emergency response plan, and inventory form are to be made available to the public at a designated location during normal working hours. Each local emergency planning…

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  • Can retail gas stations use new thresholds if USTs are not in compliance?

    How does temporary non-compliance with UST requirements affect applicability of the higher gasoline and diesel fuel thresholds for EPCRA? Retail gas stations that were not in compliance with all applicable UST requirements at any time during a calendar year may not apply the higher gasoline and diesel fuel thresholds for…

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  • Are hazardous chemicals blended for fertilizer exempted under agricultural use exemption?

    Ammonia and phosphoric acid are held for sale by a retailer in large storage tanks. The retailer sells both ammonia and phosphoric acid to farmers to be used as fertilizers. The retailer also blends ammonia with phosphoric acid to produce a new compound which, in turn, is also sold to…

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  • What else can cause urine to test positive for thiodiglycolic acid?

    Thiodiglycolic acid is commonly found in general populations who have not been exposed to vinyl chloride. Some sources can include: Certain foods including raw onions, meat, poultry, and seafood. Some medications, including Zyrtec, and vitamins. Alcoholic beverages. Smoke, including from wood fireplaces, cooking, and cigarettes. Some household products including paints…

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  • If I get a urine test for vinyl chloride, what does that indicate?

    Urine tests show the level of thiodiglycolic acid–a break-down product of vinyl chloride. A complete lab report will show your thiodiglyocolic acid results compared to the normal range commonly found in people in the United States. But this test does not reliably indicate exposure to vinyl chloride. There are several…

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  • Calculating Amounts of Fume or Dust for EPCRA 311 / 312 Reporting

    Facilities only have to count the amount of fume or dust given off a piece of metal, brick, or any other solid manufactured item that undergoes a modification process (i.e. cutting, welding, etc.) to determine whether the Emergency Planning and Community Right-to-Know Act (EPCRA) sections 311 and 312 reporting thresholds…

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  • Scope of FDA Exemption For Chemicals Used in Drugs

    Section 311(e)(1) of the Emergency Planning and Community Right-to-Know Act (EPCRA) exempts from the definition of hazardous chemicals subject to EPCRA Section 311 and 312 reporting requirements any food, food additive, color additive, drug or cosmetic regulated by the Food and Drug Administration (FDA). Are all chemicals intended for use…

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  • Are farm suppliers and retailers exempt from 311 and 312?

    Would a farm supplier or retail distributor be excluded from Sections 311 and 312 reporting based on the agricultural exemptions? Under Section 311(e)(5), retailers are exempted from reporting requirements for fertilizers only. Therefore, substances sold as fertilizers would not need to be reported under Sections 311 and 312 by retail…

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  • Are automobile batteries at a wholesaler exempted from EPCRA 311 and 312?

    A facility sells automobile batteries wholesale. Are these batteries at the wholesaler's facility exempt from reporting under SARA Sections 311/312 due to the household product exemption under SARA section 311(e)(3)? Section 311(e)(3) exempts from the definition of hazardous chemical "(a)ny substance to the extent is used for personal, family, or…

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  • Do I need to do anything to ensure my pool is safe?

    There is no current evidence of aerial deposition from the derailment that would impact pools, however ongoing soil sampling and surface water sampling will assist in further verifying the status of aerial deposition. Following these activities, messaging on private pools will be updated as necessary.

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