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EPA Proposes Revisions to Tier I and Tier II Reporting Under EPCRA

12.01.2011

On August 8, 2011, EPA proposed to revise the regulations and forms associated with Tier I and Tier II reporting under the Emergency Planning and Community Right-to-Know Act (EPCRA).  In the discussion of the proposed changes, EPA describes the revisions as adding “new data elements” to the forms that affected facilities are required to submit.  For the most part, the new information being requested is readily available to the facilities.  As an example, under the new requirements for both Tier I and Tier II forms, the facility will now be required to include the facility phone number, latitude and longitude, and the number of full time employees.

Other new “data” being required include information on a facility’s parent company and the owner or operator of the facility.  Another change will require that the facility report on the Tier I and Tier II forms whether the facility is also subject to Section 112(r) of the Clean Air Act.  The agency has also revised on the Tier I and Tier II forms how a facility reports the presence of “chemicals” and the presence of “mixtures.”  EPA has not changed the way in which these separate calculations can be made under the rule, but only how they are reported.  The comment period on this proposed rule ended on October 7, 2011.


To view a complete PDF of the Third/Fourth Quarter 2011 issue of the Environmental Letter, click HERE.

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