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Lynn L. Bergeson is managing director of Bergeson & Campbell, P.C., a Washington, D.C., law firm focusing on conventional and engineered nanoscale chemical, pesticide, and other specialty chemical product approval and regulation, environmental health and safety law, chemical product litigation, and associated business issues, and President of The Acta Group L.L.C. and The Acta Group EU Ltd. with offices in Washington, D.C., and Manchester, U.K.

EPA Proposes To Revise Emergency and Hazardous Chemical Inventory Forms

August 16, 2011
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The EPA is seeking comments about requiring the addition of information to the Tier I and Tier II forms business is required to submit each year.

On Aug. 8, 2011, the EPA proposed to revise the Emergency and Hazardous Chemical Inventory Forms (Tier I and Tier II) under Section 312 of the Emergency Planning and Community Right-to-Know Act (EPCRA) to add new data elements and revise some existing data elements. Under the proposal, the EPA is seeking the following changes:  add new data elements for facility phone number, latitude and longitude and number of full-time employees; add data elements for facility identification numbers that are assigned under the Risk Management Program under Section 112(r) of the Clean Air Act (CAA) or the TRI Program under EPCRA Section 313; require facilities to provide information on the facility's parent company and the owner or operator of the facility, such as name, address, and phone number, as well as the Dun and Bradstreet number of the facility's parent company; provide the local emergency planning committee (LEPC) with the name and contact information of a facility representative who will participate in the emergency planning process as a facility emergency coordinator; require facilities to notify LEPCs of any changes relevant to the emergency planning within 30 days after the changes have occurred (EPA believes this information should also be provided on the facility's annual inventory form since LEPCs and other emergency response coordinators may need this information during an emergency); require the name, title, phone number, and e-mail address of the person knowledgeable or responsible for completing the information on the Tier I and Tier II forms; add a new data element to indicate if facilities are subject to the emergency planning notification under EPCRA Section 302; add a new data element to both the Tier I and Tier II forms to indicate whether the facility is subject to chemical accident prevention under CAA Section 112; and expand the ranges for the reporting codes for the maximum amount and average daily amounts of hazardous chemicals present at the site in the preceding calendar year. Comments are due by Oct. 7, 2011.

Use this link to read the Federal Register announcement.
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