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Sara Title III

The Superfund Amendments and Reauthorization Act of 1986 is more commonly known as SARA Title III. This Act reauthorized the Superfund regulations as well as established community right-to-know regulations and emergency response requirements. The community right-to-know requirements were developed in response to the accident in Bhopal, India as well as several near misses here in the United States.

SARA Title III has three major sections. Section 302/304 covers emergency response notification. Section 311/312 covers Hazardous Chemical Inventory reporting and Material Safety Data Sheets. Section 313 covers the Toxic Chemical Release Inventory Reporting requirements.

Section 302/304 - Emergency Response Notification

This section currently contains a list of 360 materials deemed to be Extremely Hazardous Substances. A Reportable Quantity (RQ) and Threshold Planning Quantity (TPQ) has been established for each of the substances. Under this section, if a facility stores any of the materials at or above the TPQ, the facility must name an emergency coordinator for the facility and notify the State Emergency Response Commission (SERC), the Local Emergency Planning Committee (LEPC) and the local fire department that the facility stores one or more Section 304 substances at or above the Threshold Planning Quantity (TPQ) and supply the name of the emergency coordinator. In addition, the facility must develop and submit emergency response plans to the above agencies for their review. Finally, should there be a release from the facility which exceeds the RQ established for the material, the facility must immediately notify the National Response Center (1-800-424-8802).

Examples of substances on the Section 302/304 lists include sulfuric acid, toluene-2,4-diisocyanate, formaldehyde, and hydrogen sulfide.

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Section 311/312 - Emergency and Hazardous Material Reporting/MSDS

This section requires a facility which stores a hazardous material or an extremely hazardous material (Section 302) to submit Inventory Reporting forms to the SERC, LEPC, and the local fire department. There are two different inventory reporting forms -- Tier I and Tier II. The Tier I form contains information on each hazard category. All the materials are added together to prepare this report. The Tier II form lists each hazardous material. The inventory reporting forms require facilities to submit information on any hazardous material stored at 10,000 lb. or more on one or more days per calendar year or a Section 302 material stored at 500 lb. or more or at or above the Threshold Planning Quantity whichever is less.

EPA has defined five categories of hazardous materials:

  1. Fire Hazard includes flammable liquids and solids, pyrophoric materials, combustible liquids and oxidizers.
  2. Sudden Release of Pressure includes compressed gases and explosives.
  3. Reactive includes water reactive, organic peroxides, and unstable reactive.
  4. Immediate (Acute) Health Hazards includes highly toxic materials, toxic materials, corrosives, irritants, sensitizers and other hazardous materials which exhibit an adverse effect with short term exposure.
  5. Delayed (Chronic) Health Hazard includes carcinogens and other hazardous chemicals with an adverse effect with long term exposure.

 Information required on the reports include:

  • Facility Identification including name of owner or operator and emergency coordinator
  • Hazardous Materials with the CAS Number
  • Maximum Daily Amount stored at the facility
  • Average Daily Amount stored at the facility
  • The hazard category or categories for each material
  • General location where the material is stored
  • Number of days stored on site per calendar year
  • Container type and storage conditions (temperature
  • and pressure) Tier II reports only
  • Certification Statement

Examples of materials that would require reporting are:

  • Fire Hazard - solvents, sodium nitrite
  • Sudden Release of Pressure -- Gas cylinders such as acetylene for welding
  • Reactive Hazard -- hydrogen peroxide
  • Acute Health Hazard -- monoethanolamine, nitric acid, sodium hydroxide
  • Chronic Health Hazard -- ethylene glycol monobutyl ether, formaldehyde

Reports must be filed with the State Emergency Response Commission (SERC), The local Emergency Planning Committee (LEPC) and the local fire department by March 1 of the following year.

Section 312 requires facilities to submit Material Safety Data Sheets or lists of hazardous chemicals stored at the facility at 10,000 lb. or more or for extremely hazardous substances at 500 lb. or the at or above the TPQ whichever is less. MSDS or lists of MSDS must be submitted within 3 months of exceeding the 10,000 lb. or the TPQ thresholds.

Copes of MSDS or list Of MSDS must be submitted to the State Emergency Response Commission (SERC), The Local Emergency Planning Committee (LEPC) and the local fire department.

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Section 313 - Toxic Chemical Release Inventory Reporting (EPA Form R)

This section requires businesses in SIC Codes 20-39 to submit TRI reports on 317 chemicals and 20 categories of materials. Information on the TRI reports include:

  • Facility Identification
  • Certification Statement
  • Activities and Uses of the Chemical at the facility
  • Maximum amount on-site during calendar year
  • Releases of the chemical to air, water, land on-site
  • Identification of off-site facilities and POTW (Local Sewer Authority)
  • Transfers of wastes to off-site facilities
  • Transfers of wastewater to POTW
  • Pollution Prevention Activities at the site

Reporting is required when the facility exceeds the threshold quantity for the specific toxic material and/or chemical category. There are three reporting threshold levels under Section 313:

  1. Manufacturer or importer - must file reports if manufactured or imported exceeds 25,000 lb. in the calendar year;
  1. Processor of material - must file reports if lb. processed exceeds 25,000 lb. in the calendar year;
  1. Otherwise used - used in a process as a manufacturing aid such as coolant or cleaner or used in an ancillary process such as waste treatment - must file reports if lb. used exceed 10,000 lb. in a calendar year.

Customers using Quaker products fall under the otherwise used definition for reporting purposes.

Examples of materials requiring TRI reporting are: diethanolamine, glycol ethers, perchloroethylene, chromium compounds.

To determine if the facility is required to report:

1. Is the facility SIC Code in the range of 20-39?

2. Does the facility employ 10 or more full-time employees?

3. Did the facility otherwise use 10,000 lb. or more of a listed chemical?

Suppose the facility used 50,000 lb. of a coolant which contains 10% glycol ether. They also use 75,000 lb. of a cleaner which contains 10% glycol ether. The coolant usage would contribute 5,000 lb. of glycol ether; the cleaner would contribute 7,500 lb. of glycol ether. Total usage would be 12,500 lb. of glycol ether which would require the filing of a Form R report.

Another example would be a coolant which contains 3% diethanolamine and the facility uses 10,000 gallons of coolant in the year. The total amount of DEA used would be 2499 lb. (assuming that the coolant weights 8.33 lb./gal.). No reports would be required.

Reports must be filed with the U.S. Environmental Protection Agency and the State Emergency Response Commission (SERC) by July 1 of the following year.

If you have any additional questions, please feel free to contact the Safety, Health & Environmental Group.

PREPARED BY: Kathryn F. Strang
Manager, Safety, Health & Environmental
August 1, 1997


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