Differences between the risk management program and EPCRA
How do the Clean Air Act (CAA) risk management program requirements differ from the hazardous chemical reporting requirements under the Emergency Planning and Community Right-to-Know Act (EPCRA)?
The hazardous chemical reporting requirements under EPCRA sections 311 and 312 (40 CFR Part 370) are separate and distinct from those under CAA section 112(r) (40 CFR Part 68). EPCRA hazardous chemical inventory reporting (on Tier I or Tier II forms) applies to all hazardous chemicals, as defined by the Occupational Safety and Health Administration, with certain exemptions (40 CFR 370.13). Information reported under the hazardous chemical inventory regulations includes the types and amounts of hazardous chemicals, location and storage information, and facility contact information. The CAA risk management program rule applies to a distinct set of regulated substances listed at 40 CFR 68.130. The risk management program requirements go beyond emergency planning and reporting; they require a holistic approach to accident prevention and mitigation. Elements required under the risk management program regulations vary for individual stationary sources, but generally include a hazard assessment, a prevention program, an emergency response program, and a management system.