GECAP Georgia Environmental Compliance Assistance Program http://www.gecap.org SARA Title III Section 313 Toxic Chemical Release: Reporting Requirements GECAP of the Georgia Tech Research Institute is a voluntary, non-regulatory environmental compliance program funded by the Georgia Legislature through the University System of Georgia.

What is the SARA Title III §313 Community than 500 pounds; or Right-to-Know Program? • facility has an “annual reportable amount” less than Section 313 Emergency Planning and Community 500 pounds but facility manufactures, processes, or Right-to-Know Act (EPCRA), which is also known otherwise uses more than 1 million pounds5. as Title III of the Superfund Amendments and Criteria for reporting a chemical with Form A: Reauthorization Act (SARA), requires certain facilities to report both routine and accidental chemical • facility meets all the criteria previously mentioned releases. These businesses must submit reports to the for Form R except… Environmental Protection Agency (EPA) and the state • facility has an “annual reportable amount”4 of less emergency response commission (SERC) by July 1 for than 500 pounds6; and each preceding year. • facility manufactures, processes, or otherwise uses Which facilities must submit Toxic Chemical less than 1 million pounds5. Release Inventory forms? A flow chart for determining applicability of EPCRA EPA’s “Toxic Chemical Release Inventory Reporting §313 requirements is provided at the end of this Tech Form R and Instructions” provides guidance on how Guide. to determine if your facility must submit a report. Either Form A or Form R must be sent to the EPA and Where do facilities send the forms? SERC if a facility is required to comply with EPCRA Facilities must report the quantities of both routine §313. Choosing the correct EPA Form depends on the and accidental releases of listed toxic chemicals, the type and quantity of chemicals at the facility. maximum amount of each chemical on-site during the calendar year and the amount contained in wastes Criteria for reporting a chemical with Form R: transported off-site. The reports are sent to the EPA • facility has 10 or more full-time employees; and and the SERC in a written or electronic format. • facility is included in Standard Industrial The Georgia SERC contact information is: Classification (SIC) codes 10, 12, 20-39, 4911, 4931, 4939, 4953, 5169, 5171, 73891 or is a federal Judson H. Turner, Director facility; and Georgia Environmental Protection Division Director’s Office • chemical is subject to reporting under Section 313 2 Martin Luther King Jr Dr SE Ste 1456 East column of SARA Title III “List of Lists”2 (i.e. is Atlanta, Georgia 30334-9074 a listed chemical), which is also listed in 40 CFR 372.65; and The EPA address is as follows: • facility manufactures or processes more than 25,000 U.S. Environmental Protection Agency pounds/year of a listed chemical or facility otherwise Attention: TRI Reporting Center uses more than 10,000 pounds/year of a listed P.O. Box 10163 chemical3; and Fairfax, VA 22038 • facility has an “annual reportable amount”4 of more What is the Hazardous Substance Reporting Fee? • Contact the Georgia Environmental Compliance Assistance Program (GECAP) at Georgia Tech by The Georgia Environmental Protection Division calling 404-407-8082. Sections(EPD) 311institutes & 312a hazardous — Hazardous substance reporting Chemical fee Inventory Reporting Refersassociated to the pr withesen cethe, aEPCRAt any on e§313 time submittal., of a chemi Thiscal t hafeet isis required• For trelatedo have informationa Material Safe seet ythe Da followingta Sheet (MSDS GECAP) by the Occupationaldue July 1Safety of each and year. Health The Administration basic fee schedule (OSHA) is: $575 Hazard CommunicatiTech Guides:on EPCRA Standard Sections (HCS). 302-303; EPCRA annually for §313 reported releases between 1 and 999 Section 304; EPCRA Sections 311 and 312; and pounds;STEP $1150 1: annually for §313 reported releases EPCRASTEP. 2: between 1,000 pounds and 10,000 pounds; and $1725 Does the facility have Is the facility required by 1 annually for §313 reported releases greater than or Exemptionsany ch andem limitationsical considered associated with certain OSHA HCS to have an equal to 10,000 pounds. Fees are based upon total SIC codes.to be Refer an E HtoS the per EPA’s the “Toxic Chemical Release poundsMSDS released for annually.a chemical? Inventory Reporting Forms and Instructions” for more details.EPA List of Lists? For MoreNO Information YES NO YES 2 “Title III List of Lists” is a consolidated list of chemicals • Visit EPA’sIs th Toxicsere ≥ 1 Release0,000 lb Inventorys of homepage at subject Itos tthehe EmergencyEHS ≥ 500 Planning lbs or and Community http://www2.epa.gov/toxics-release-inventory-tri-this chemical on Right-to-KnowTPQ (whichever Act (EPCRA) is lower) and Section 112(r) of the Clean Air Act. programsite at any one time? on site at any one time? NO YES 3 “Manufactures,”NO “processes,”YES and “otherwise uses” have • You can also obtain a copy of SARA Title III “List of activity thresholds and are defined thoroughly in EPA’s Lists,” Form R, Form A, and instructions by calling “Toxic Chemical Release Inventory Reporting Forms and Do any exemptions apply? Do any exemptions apply? the EPCRA Hotline at 800-424-9346 or Instructions.”

703-412-9810. 4 YES NO An “annual reportableYES amount”NO is a total of all releases including all quantities used for energy recovery on site • Information on Georgia’s Hazardous Substance Facility must report MSDS. and off site, recycled Fonac siteilit yand mu offst rsite,epo randt EHS. treated on Reporting Fee can be found in Section 3.0 of site and off site. the Guidelines for Calculating Hazardous Waste 5 Management FeesFa andcilit yHazardous does not Substancereport MSDS. Reporting Facilities that releaseF alesscil ithanty d o500es npoundsot rep ofor ta EHS.listed chemical are eligible for the “alternative threshold” of 1 Fees, located at: http://epd.georgia.gov/sites/epd. million pounds manufactured, processed, or otherwise georgia.gov/files/related_files/site_page/fee_guide. used. The “alternative threshold” is applied per chemical Sectionpdf or 313 by calling — Toxic the EPD Release Hazardous Inventory Site Response for each different activity. Program at 404-657-8600. Addresses the release (routine or accidental) of certain toxic chemicals6 If facility found has no in release,the EPA the List owner of and/orListstha operatort are is still manufactured, processed, or otherwise used in the calendar year.required to submit a Form A according to §313 EPCRA.

Does facility Does facility Is the facility Does facility manufacture, manufacture classified under YES YES YES have ≥ 10 full- process, or or process ≥ the SIC codes in time employees otherwise use 25,000 lbs/year EPCRA §313 or a a listed or otherwise federal facility? chemical use ≥ 10,000 NO under EPCRA lbs/year of this §313? chemical? NO

NO NO YES

Facility does not report. Facility must report.

Updated 9/2014 updated 3/07 For more information, contact GECAP: Printed on Georgia Tech Research Institute For moreAtlanta, information, Georgia 30332-0837 contact the Tech Assist Program recycledPrinted paper on Health404-407-8082 and Environmental http://www.gecap.org Systems Laboratory Environmental Systems Division, Atlanta, Georgia 30332-0837 404.407.8645 http://www.gtassist.org recycled paper