HRP Associates, Inc - EPA Has Increased EPCRA Enforcement

EPA HAS INCREASED EPCRA ENFORCEMENT

US EPA has increased EPCRA enforcement compliance in Region I. EPCRA (Emergency Planning and Community Right-to-Know Act) requirements include these four components:

MSDS Reporting
Extremely Hazardous Substance Notifications
Tier II Reports – Inventory of Hazardous Substances, due March 1st, annually
Form R Reports – Toxic Release Inventory, due July 1st, annually

EPA conducted a series of Tier II inspections in 2008-2009, and is currently conducting Form R inspections in 2009-2010. Typically, an EPA inspector spends several hours “walking through” all facility raw materials, processes, wastes, and by-products. The inspections are comprehensive and time-consuming, and many have resulted in significant fines for failure to report (up to $37,500 per day) certain compounds, or failure to report at all.

Through recent years, reporting requirements and procedures have changed. It is not good enough to assume that “what you reported last year” is what you are required to report this year.

HRP Associates, Inc. recommends taking the opportunity in 2010 to thoroughly review your reporting obligations. Do not take it for granted that past Tier II and Form R reports can be repeated year after year.

Should you have any questions, please contact HRP Associates, Inc. at any time.

Email: Joseph Magdol, P.E., LEP

Toll Free: 800-246-9021
Phone: 860-674-9570