Toxic Chemical Reporting: How to Comply

Many coating facilities are subject to one or more provisions of the Emergency Planning and Community Right-to-Know Act (EPCRA). The purpose of this law is to require industry to provide information about the type, amount, and location of chemicals they keep on-site and to report information about releases of toxic chemicals from their facility. Local planners and response personnel use this information to respond to chemical emergencies and this information is available to the public.

EPCRA Sections 311 and 312 require facilities to submit information about chemicals on-site and Section 313 deals with chemical releases from the site.

EPCRA Sections 311 and 312 are applicable to facilities that are

regulated by Occupational Safety and Health Act's (OSHA) Hazard Communications Standard and
exceed established thresholds for hazardous chemicals on site at any one time.

EPCRA Section 313 reporting requirements apply to facilities that have

10 or more full-time employees and

use a listed toxic chemical in excess of the threshold quantities.

To meet the requirements of these regulations, applicable facilities must:

Section 311 - One time, submit material safety data sheets (MSDS) to specified local planners and response personnel
Section 312 - Each year provide an inventory of MSDS chemicals at your facility
Section 313 - Each year report information about releases of hazardous chemicals from your facility
Recordkeeping - Maintain records, including forms and supporting documentation (e.g., calculations) for a period of three years after due dates.

Use the above links to find details about each of these reporting requirements.