If your facility falls under Emergency Preparedness and Community Right-to-know Act (EPCRA) requirements, there’s more to do then just TRI reporting. Here’s a checklist to help you make sure you cover you bases with all the regulations.
Have the requirements handy
- Do you have copies of the statute?
- Do you have copies of the federal, state, or local regulations?
Does management know they need to be compliant?
- Have you informed management of impending regulations?
Which personnel has which duties?
Have key personnel needed for program development and implementation been identified and notified?
- Administration
- Public Relations
- Health and Safety
- Production:
- Environmental
- Purchasing
- Attorney
Has there been an informational meeting scheduled with all key personnel?
Informing/training personnel
During the meeting, did you…
- Distribute information on the regulations?
- Give presentation on the law?
- Discuss the impact of the law?
- Establish the need for a unified implementation effort?
Did you discuss company policy relating to…
- Emergency planning?
- Extent of cooperation with local officials?
- Chemical reporting?
- Risk communication?
- Trade secrets?
Misc. Tasks
Have you:
- Developed a strategic compliance plan?
- Incorporated growth plans (i.e., new processes, new facilities) into the plan?
- Reviewed the existing site emergency response plan?
- Notified state and local officials that you are covered by the law?
- Developed a facility timetable for compliance?
- Reviewed the program to ensure that it addresses the salient issues?
- Submitted the program to key personnel for approval?
- Assigned personnel and defined specific tasks to achieve compliance with each applicable requirement?
- Have you identified the EPA contacts, the SERC, the LEPC, and the local fire chief?
- Do you have an established relationship with state and local emergency response officials?
- Have you named a facility emergency coordinator?
- Has this person met with key EPCRA officials?
- Have you developed a public relations program for the dissemination of chemical information to the community?
- Have filing and documentation systems been devised to record all EPCRA compliance activities?
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