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SPCC Qualified Facilities Substantial Harm Criteria Certification

Are SPCC qualified facilities required to complete and maintain a copy of the Certification of the Applicability of the Substantial Harm Criteria form located in Appendix C of 40 CFR Part 112?

Yes, all SPCC regulated facilities, including qualified facilities, that do not meet the criteria of a substantial harm facility, must complete and maintain this form at their facility (40 CFR 112.20(e)).  There are no exceptions for qualified facilities.