civil penalties

February 20, 2017

Understanding and correcting typical Tier II deficiencies may help companies with hazardous chemical reporting obligations avoid the recently increased penalties.

 

On March 1, each year facilities that use hazardous chemicals in specific quantities must file an EPCRA Tier II report identifying the chemicals with the State Emergency Response Commission, the Local Emergency Planning Committee, and the local fire department.

Easy to avoid mistakes and omissions in Tier II filings may lead to civil penalties of as much as $54.8K per day. Most cited violations involve just a few common chemicals such as ammonia, sulfuric acid inside equipment, and an EHS that is a component of mixtures. These are often overlooked or thought to be exempt from reporting because the threshold for reporting may be low.

Rather than risk non-compliance, ask the professionals at SCS Engineers about common chemical thresholds, voluntary self-disclosure, and EPA’s audit policies.

Read our most recent EPCRA Technical Bulletin, or contact us at .

Posted by Diane Samuels at 3:00 am