Community-Right-To-Know (CRTK) Primer

EPCRA requires industry to report on the storage, use and releases of hazardous substances to federal, state, and local agencies.

• About 500,000 products are covered to report under hazardous chemical storage requirements (Section 311/312).
• About 650 toxic chemicals and categories are covered to report under toxic chemical release inventory (Section 313).
• About 1000 chemicals are covered to report under emergency notification requirements (Section 304). This includes 356 extremely hazardous substances (EHS) covered under Section 302.

Take the following quiz to test your knowledge of the EPCRA regulatory requirement.

• Does the site have an inventory of chemicals and their threshold planning quantities (TPQ)?
• Does the site submit MSDSs (or SDSs), or a list of hazardous chemicals, to their State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC) and local fire department?
• Does the site maintain an up-to-date release notification procedures?

We have noticed the following errors and omissions in the EPCRA reports:

• Lack of up‐to‐date SDS (MSDS are no longer accepted)
• Lack of accurate inventory
• Failure to recognize EHS
• De minimus chemicals – any hazardous chemicals that are 1% or more of a mixture must be reported (see SDS); carcinogens more than 0.1% must be reported
• Identifying when to list a mixture and when to list a pure chemical
• Industrial batteries containing sulfuric acid
• Manufacturing support materials
• Residual in drums

It is recommended that facilities periodically evaluate its compliance with the EPCRA regulations using an independent consultant. Contact Sam Joshi, P.E. at (215) 389-2811 if you have any questions.