Tag: EPCRA

Clearing Up Confusion About EPCRA Responsibility

Defining responsibility for EPCRA compliance on a site can often lead to questions that apply only to that particular situation or event. One such situation is that of chemicals brought on a site by contractors hired to perform work and where reporting responsibility lies—with the facility owner/operator or with the contractor. According to the Environmental […]

Clearing Up Confusion About EPCRA Exemptions

One of the most confusing exemptions under EPCRA is that for “routine agricultural use” (Section 311(e)(5)) under Sections 311 and 312, which cover Safety Data Sheet (SDS) reporting and Tier I/Tier II Inventory reporting, respectively. According to the Environmental Protection Agency (EPA), the exemption is “designed to eliminate the reporting of fertilizers, pesticides, and other […]