EPCRA applicability determination, Tier II chemical inventory reporting, TRI Form R and release notification obligations — handled on a calendar so a March 1 deadline does not arrive unnoticed.
Extremely hazardous substances carry threshold planning quantities far below the general ten thousand pound level. A modest quantity of an EHS chemical pulls you into obligations most facilities assume do not apply.
Reporting triggers on the maximum amount present at any point during the year. A single large delivery in July creates an obligation even if average inventory sits well below threshold.
Reporting is only as good as the underlying inventory. A list maintained separately from purchasing drifts within a year, and the report is then wrong rather than late.
TRI applies based on SIC or NAICS code, employee count and manufacturing, processing or otherwise-use thresholds. Many facilities have never formally checked and assume they are out.
Reportable quantity releases require immediate notification to specific bodies. Facilities discover this obligation during the release, which is the worst possible time.
Annual obligations with no named owner are missed once and then missed every year, because nothing surfaces the gap until an inspection.
We start with a defensible applicability determination across EPCRA sections — planning notification, Tier II inventory, TRI and release reporting — based on your actual chemical inventory, stored maximums and facility classification.
Then we prepare and submit the reports, maintain the inventory reconciliation that keeps them accurate, and put every deadline on a compliance calendar with a named owner and lead time, so a submission is never discovered late.
March 1 each year for the prior calendar year, submitted to the state commission, the local emergency planning committee and the local fire department. Several states use their own submission system with additional fields and fees.
Late submission is better than continued non-submission, and voluntary disclosure policies may apply. Handle it deliberately rather than quietly filing and hoping nobody compares years.
Commonly yes, and fuel is one of the most frequent reasons a facility crosses threshold without realizing it. Stored fuel, oils and even certain gases in cylinders add up.
Different programs with different triggers. Tier II is inventory reporting under EPCRA; SPCC is spill prevention under the Clean Water Act oil rules. Facilities often need both and confuse them routinely.
Yes, with your authorization. We prepare, you review and approve, and we file and retain the confirmation.
Twenty minutes to run a threshold analysis against what you actually stored last year.
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