Hazardous Materials Disclosure Reporting

Hazardous Material Business Plan (HMBP)

HMBPs also fulfill the fire code requirement to prepare Hazardous Materials Management Plans (HMMP) and federal requirements under EPCRA to file a Tier II Report. These amounts are as follows: 

  • 55 gallons of a liquid
  • 500 pounds of a solid
  • 200 cubic feet of a gas

Hazardous materials in California may include hazardous substances, hazardous waste, and any material that could be damaging to health or to the workplace environment. 

The Emergency Planning and Community Right-to-Know Act (EPCRA) was passed in 1986 in response to concerns regarding the environmental and safety hazards posed by the storage and handling of toxic chemicals. This law requires regulated facilities that store any hazardous or extremely hazardous substances above threshold planning quantities to compete a Tier II Report. This report includes information about the facility, employee contact information, and an inventory and location of the chemicals used at the facility. This report is required to be updated upon significant changes at the facility and at least annually prior to March 1st of each year. Many states and municipalities have strengthened the aforementioned EPCRA reporting requirements. These requirements vary widely by state and local municipalities, but generally require employers to develop site plans detailing storage areas, reduced reporting thresholds, and regular compliance inspections.

Hazardous Material Business Plan Services

Our organization can take care of the following:

Services
  • Prepare the annual Hazardous Material Business Plan for submission to the local regulating agency
  • Report all chemicals which exceed the thresholds established 
  • Prepare a detailed site map showing the hazardous materials storage areas and emergency equipment
  • Prepare the emergency response and contingency plan 
  • Evaluate and update the plan as the operating conditions change
  • Employee training
  • Annual environmental compliance audit

Toxics Release Inventory 

The Emergency Planning and Community Right To Know Act outline in section 313 that the EPA Toxic Chemical Release Inventory Report Form be filed annually by July 1 by the owners or operators of facilities that meet the following requirements:

Requirements
  • The facility employees have worked a total of 20,000 hours or more during the reporting year (i.e., equivalent to 10 or more full-time people)
  • The facility is included in the NAICS codes: 311*, 312*, 313*, 314*, 315*, 316, 321, 322, 323*, 324, 325*, 326*, 327*, 331, 332, 333, 334*, 335*, 336*, 337*, 339* and select other NAICS codes (corresponding to SIC codes 20 through 39)
  • The facility manufactured, processed in excess of 25,000 pounds, or otherwise used in excess of 10,000 pounds of any Section 313 Toxic Chemicals during the reporting year or exceeded thresholds for listed Persistent, Bioaccumulative, and Toxic (PBT) Chemicals

 

It must be noted that every year chemicals are added to and taken away from the Form R list. This is why companies must be up to date and need to reevaluate reportable chemicals every year. Some chemicals have proposed reporting levels as low as 1 pound per year.

Section 313 of EPCRA established the Toxics Release Inventory. TRI tracks the management of certain toxic chemicals that pose a threat to human health and the environment. Manufacturers and processors with specific SIC and NAICS codes with at least 10-full time employees and who manufacture or process a minimum of 25,000 pounds of extremely hazardous substances, or use 10,000 pounds per calendar year must submit an annual toxic chemical release form. This form includes technical information about the annual amount of chemicals released to the air, water, land or off-site transfers for disposal or other waste management activity. This report is due on an annual basis by July 1st of each year. 

Failure to comply with any EPCRA requirement may result in a civil penalty of up to $70,000 per violation per day. 

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