It is that time of year again. Reporting year 2008 Form R (or Form A) reports as required by Section 313 of the Emergency Planning and Community Right to Know Act (EPCRA) are due by July 1, 2009.
The new EPA administration has stated that it will increase its focus on enforcement, and EPCRA violations are near the top of the list. In fact, several of our clients in Region IV have been visited by EPA inspectors conducting EPCRA spot-checks. If your facility has not submitted these yet for reporting year 2008, make sure that someone is working on it. Any facility that manufactures, processes, or otherwise uses a Section 313 chemical in quantities over the reporting threshold is required to submit a Form R to the EPA and state agency each year that they meet the reporting threshold.