Environmental Consulting

Chemical Inventory Reporting

Streamline EPCRA compliance with expert SDS/Tier II reporting, audits, hazard analysis, and cross-media impact management for chemical safety from Trinity.

In today's environmentally conscious landscape, the safety and transparency of chemical usage in facilities are paramount. The Emergency Planning and Community Right-to-Know Act (EPCRA) sets stringent guidelines for chemical inventory reporting to protect public health, safety, and the environment.

Trinity Consultants offers expert services in SDS/Tier II reporting, audits, and hazard analysis, ensuring facilities meet stringent environmental standards.

Trinity Consultants staff have been providing the following services since the inception of EPCRA:

  • Report/Notice preparation
  • Tier II/SDS Report review
  • Compliance audits
  • Hazard review & modeling
  • SDS creation through our Redstone Group
  • Managing cross-media impacts from chemical changes (RMP, PSM, CFATS, TRI, Air, TSCA, SWPPP, RCRA, SPCC)

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Our Results

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Regulatory Background

Who May Need Chemical Inventory Reporting Support and Why?

What is the Chemical Inventory Reporting Rule under EPCRA?

The Emergency Planning and Community Right-to-Know Act (EPCRA) is designed to help local communities protect public health, safety, and the environment from chemical hazards. Facilities must maintain a material Safety Data Sheet (SDS) for any hazardous chemical used or stored. Facilities must submit SDSs, or a list of hazardous chemicals, to their State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC) and local fire department.

Facilities must also submit an annual inventory (Tier II) of these chemicals by March 1 of each year to their SERC, LEPC and local fire department. Some states have additional reporting requirements. The information submitted by facilities must be made available to the public.

Does your facility need to make these reports?

Any facility that is required to maintain SDSs under the Occupational Safety and Health Administration (OSHA) regulations for hazardous chemicals stored or used in the workplace is subject to reporting if the amounts stored exceed certain thresholds. There is no list of reportable chemicals. EPA estimates that over 500,000 chemicals/products present OSHA hazards and are thus reportable.

What is the Emergency Planning Rule under EPCRA?

The Emergency Planning Rule allows LEPCs to develop local emergency response plans to address hazards posed by extremely hazardous substances. You must comply with the emergency planning requirements if your facility meets either of the following two conditions: (a) Any extremely hazardous substance (EHS) is present at your facility in an amount equal to or greater than its threshold planning quantity (TPQ), or (b) your facility has been designated for emergency planning purposes.

Important Dates / Deadlines

SDS reporting is a one-time submittal. New facilities have three months after becoming subject to the OSHA regulations to submit their SDSs or the list of the hazardous chemicals to their SERC, LEPC, and the fire department. Existing facilities also have to update the report if an SDS indicates new hazards, compositions change, or if any unreported chemicals exceed the reporting thresholds.

Facilities that need to submit SDSs or the list of hazardous chemicals also need to submit an annual inventory report for the same chemicals. This inventory report must be submitted to the SERC, LEPC and local fire department by March 1 of each year in most states.

A facility subject to Emergency Planning must notify the SERC and the LEPC within 60 days after they first receive a shipment or produce the substance on site at or above the TPQ. The facility must also notify the LEPC of a facility representative who will participate in the emergency planning process and provide notice within 30 days of any changes relevant to emergency planning.

Partnering with Trinity

Let’s collaborate. What can we help you achieve?

We invite you to contact us with your specific challenges. Let’s see how we can succeed together! Contact us to discuss how we can work together and achieve your goals. 

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