Regarding the written follow-up report to an incident, should location of the incident and the cause of the incident be included?

The April 22,1987 Federal Register (52 FR 13387) states that the location of the incident should definitely be included in both the initial and written follow-up reports.  However, the cause of the accident is not addressed and it is not required in the regulations pursuant to Section 304 of EPCRA.  EPA strongly encourages, but does not require the inclusion of the incident in the written follow-up report.