EPA Chemical Reporting Deadline Is March 1

All facilities, including dairy operations, are required by the Environmental Protection Agency (EPA) to report their inventories of hazardous chemicals, including many cleaning and sanitizing agents and other maintenance chemicals (if certain thresholds are exceeded) every year by March 1. IDFA urges member companies to ensure that all operations are in compliance with EPA reporting requirements. Fines for non-compliance can be significant.

Section 312 of EPA's Emergency Planning and Community Right-to-Know Act (EPCRA) requires individual facilities to report their storage and inventory of hazardous and toxic chemicals using chemical inventory forms — either Tier I or Tier II forms depending on state law. The forms must be filed with the State Emergency Response Commission, Local Emergency Planning Committee and local fire department.

This requirement is not the same as the annual reports known as the Toxic Release Inventory (TRI) or Form R reports, which are due July 1 under EPCRA Section 313.

For more information, contact Clay Detlefsen, IDFA vice president, at cdetlefsen@idfa.org, 202-220-3554, or visit www.epa.gov/OEM/content/epcra/tier2.htm#state.

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Posted January 14, 2008