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  • Heather Cummings

EPA Manufacturing Compliance

Updated: Aug 29, 2023

With the new year comes new deadlines, and EES wants to ensure your company is prepared for all upcoming state and federal compliance deadlines. There are three important deadlines that are quickly approaching for manufacturing industry:

Tier II Deadline: March 1st

If we haven’t scheduled your Tier II reporting yet, what are you waiting for?

Facilities covered by the Federal Emergency Planning and Community Right-to-Know Act (EPCRA) requirements must submit an Emergency and Hazardous Chemical Inventory Form to the Local Emergency Planning Committee (LEPC), the State Emergency Response Commission (SERC), and the local fire department annually by March 1st.

Minimum thresholds have been established for Tier II reporting under Title III, Section 312. These thresholds are as follows:

  • For Extremely Hazardous Substances (EHSs) designated under section 302 of Title III, the reporting threshold is 500 pounds (or 227 kg.) or the threshold planning quantity (TPQ), whichever is lower;

  • For all other hazardous chemicals for which facilities are required to have or prepare an MSDS, the minimum reporting threshold is 10,000 pounds (or 4,540 kg.).

  • By March 1st, you need to report hazardous chemicals that were present at your facility at any time during the previous calendar year at levels that equal or exceed these thresholds.

Air Emissions Inventory: March 1st for most states

Each has slightly different requirements, but each mandates an annual inventory of air emissions to the atmosphere. The inventory must include a list of all criteria pollutants [oxides of nitrogen, carbon monoxide, sulfur dioxide, particulate, ground-level ozone (through reporting of VOC) and lead] and hazardous air pollutants. The Annual Emission Statement is due to the state agency by March 1st (in most cases).

Reporting data can include stack tests, Continuous Emissions Monitoring data, material balance calculations and industry-specific emission factors.

SARA 313 – Toxics Release Inventory Deadline: July 1st

The Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA), Title III, Section 313, also known as the Superfund Amendment and Reauthorization Act (SARA), requires that annual reports be filed by owners and operators of facilities that meet specific criteria to report the quantity of SARA 313 chemicals used, released, and transferred at each facility. SARA 313 requires the EPA and state regulatory agencies to annually collect data on releases and transfers of certain toxic chemicals from industrial facilities, and make the data available to the public through a public database called the Toxics Release Inventory, or TRI.



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