Emergency Preparedness and Response

EPCRA Compliance Checklist


Yesterday we told you about a couple of gold mines that settled with EPA to pay a $618,000 fine for failure to correctly submit TRI Reports. EPCRA Section 313 requires manufacturing facilities to submit an annual toxic chemical release report that allows the EPA to compile the national TRI database. But, if your facility falls under EPCRA requirements, there’s more to do then just TRI reporting. Here’s a checklist to help you make sure you’ve got those regs covered from A to Z.

  • Do you have copies of the statute?
  • Do you have copies of the federal, state, or local regulations?
  • Have you informed management of impending regulations?

Have key personnel needed for program development and implementation been identified and notified?

  • Administration
  • Public Relations
  • Health and Safety
  • Production:
  • Environmental
  • Purchasing
  • Attorney

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Has there been an informational meeting scheduled with all key personnel?
During the meeting, did you:

  • Distribute information on the regulations?
  • Give presentation on the law?
  • Discuss the impact of the law?
  • Establish the need for a unified implementation effort?

Discuss company policy relating to:

  • Emergency planning?
  • Extent of cooperation with local officials?
  • Chemical reporting?
  • Risk communication?
  • Trade secrets?

Have you:

  • Developed a strategic compliance plan?
  • Incorporated growth plans (i.e., new processes, new facilities) into the plan?
  • Reviewed the existing site emergency response plan?
  • Notified state and local officials that you are covered by the law?
  • Developed a facility timetable for compliance?
  • Reviewed the program to ensure that it addresses the salient issues?
  • Submitted the program to key personnel for approval?
  • Assigned personnel and defined specific tasks to achieve compliance with each applicable requirement?
  • Have you identified the EPA contacts, the SERC, the LEPC, and the local fire chief?
  • Do you have an established relationship with state and local emergency response officials?
  • Have you named a facility emergency coordinator?
  • Has this person met with key EPCRA officials?
  • Have you developed a public relations program for the dissemination of chemical information to the community?
  • Have filing and documentation systems been devised to record all EPCRA compliance activities?

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