Overview of EPCRA 311/312 changes effective January 1, 2018

The Environmental Protection Agency (EPA) is revising existing hazard classes to conform to the Occupational Safety and Health Administration (OSHA) Hazard Communication Standard.

Current 311/312 hazard categories:

• Fire
• Sudden Release of Pressure
• Reactive
• Immediate (Acute)
• Delayed (Chronic)

New 311/312 hazard categories:

Many states have their own software for hazardous chemical inventory reporting. Other states use Tier2 Submit, electronic software developed by EPA. Note that the interface of these software will change significantly to include the revised hazard categories.  For reports due by March 1, 2018, facilities reporting under Sections 311 and 312 will be required to report the revised physical and health hazards for the hazardous chemicals present during the 2017 calendar year.

It is recommended that facilities prepare as soon as possible for the upcoming EPCRA 311/312 changes. At a minimum, appropriate physical and health hazards should be allocated to the anticipated list of reportable hazardous substances. Contact Sam Joshi at (215) 389-2811 if you have any questions.