Chemicals, EHS Management

Reporting Requirements for Hydrogen Peroxide under EPCRA

Q. What are the regulations surrounding Hydrogen Peroxide, 50% solution? Is it considered an extremely hazardous substance (EHS)? What are the reporting requirements under EPCRA?

A. Hydrogen Peroxide, 50% solution, is a hazardous chemical for which employers must maintain a Safety Data Sheet (SDS) and is therefore subject to the hazardous chemical reporting requirements under EPCRA Sections 311 and 312 (40 CFR 370) if it is present at a facility at any one time in an amount equal to or greater than 10,000 pounds (the threshold planning quantity, or TPQ).

Under EPCRA Section 311, a facility must submit the hazardous chemical’s SDS, or a list of such hazardous chemicals that exceed TPQs, to the State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC), and the local fire department within 3 months after they become covered.

Under EPCRA Section 312, facilities storing hazardous chemicals above TPQs must submit an annual Emergency and Hazardous Chemical Inventory Form (Tier I or Tier II form, depending on the state) to the SERC, the LEPC, and the local fire department. The inventory must be submitted on or before March 1 each year for information on chemicals present at the facility in the previous calendar year.

Hydrogen Peroxide, 50% solution, is not considered an EHS. However, Hydrogen Peroxide at a concentration greater than 52% would be considered an EHS and would be subject to the emergency planning and release notification requirements found under EPCRA Sections 302 and 304 (40 CFR 355).