|What the regs require |
|The Environmental Protection Agency’s (EPA) SARA Title III requires certain reporting based on the chemicals that are manufactured, used, stored, or processed at your facilty(s). The SARA Title III reporting requirements are due March 1st (Tier II) and July 1st (TRI) each year. |
Failure to comply with either of these regulations can result in fines up to $25,000/day/occurrence.
|Do any of these regulations affect me? |
|This is the first and most critical answer that every facility must ultimately answer. The next few simple questions will help you answer the above. If you can answer “No” to any of the following questions then you’re in the clear: |
Question #1: Do you do any one of the following; manufacture, use, store or process chemicals? (The simplified definition for “chemical”, pertaining to these regulations, is a product that you are required to maintain a MSDS. They include solids, liquids and gases.)
Question #2: Do you have chemicals contained within these products that fall on any of these lists? (This one is a little more difficult; however, if the answer to question #1 was “Yes” then the answer to this one is most likely the same.)
Question #3: Do any of these “Chemicals”, either by themselves or aggregated (based on your maximum amounts on any given day or annually), meet or exceed the reporting thresholds listed in SARA Title III? (The only way that we can help you with this one is to screen for them.)
Note: Even if you answered “No” to either question 2 or 3 you still may have a requirement if you have any chemical that exceeds 10,000 lbs on hand any given day at you facility.
|Our View: E&SSG has provided chemical screening services that have helped our clients cut through the regulatory red tape of regulated chemicals for more than 17 years. |
E&SSG has developed many systems to effectively track your chemical inventory and provide you "Peace of Mind" about your chemical requirements.
|What We Offer |
|SARA Title III Screening Service |
|This service is designed to virtually eliminate the amount of time you would spend studying the SARA Title III regulations as well as searching, cross-referencing and indexing your chemical inventory against the SARA Title III regulated chemical lists. |
This simple and painless service provides you with vital, “site specific”, information on how your facility(s) stand up against these regulatory lists and regulations.
After this service is complete, it will be clear what areas of these regulations your facility(s) need to be concerned with or (better yet) have the defensible documentation to show that they don’t affect you.
|The entire process can be completed in as little as a few days.* |
|Initially you simply provide to us copies of your Material Safety Data Sheets (MSDS) that represents your current chemical product inventory. |
|Our staff of trained professionals enter key information from your MSDS into our system. |
|We send you back either an E-mail or hardcopy** form requesting your product inventory information on the just the products, present at your facility, that contain these regulated chemicals. This information includes your quantities, container types, areas stored and areas used. |
|Logical ||After the information is received back from you and entered into your file, E&SSG's proprietary CIA software matches your inventory against the thousands plus of regulated SARA Title III and Chemicals. |
|The reports of the findings and/or compliance instructions are then delivered back to you in a three ring binder and/or PDF format.** |
|The reports that you receive will provide you with supportable documentation as well as a management tool to assess your hazards. This includes the following 7 reports complete with detailed information showing your: |
• Basic Total Chemical Inventory***
• Emergency Release Priority Products
• Extremely Hazardous Substances (EHS) Chemicals
• Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) Chemicals
• TRI (Form R/A) Chemicals
• 10,000 lb. Chemicals
• Process Safety Management Chemicals
|Ongoing ||This service is a renewable annual (12 month) service that allows you to provide us your new or revised MSDSs as your chemical inventory changes. This allows us to monitor the changes in your inventory along with the ongoing modifications to the SARA Title III lists and notify you if your status changes |
|Next Steps |
|Depending on the findings in your screening reports, there are potentially several additional steps for you to be fully compliant with all the sections listed. These steps could include additional analysis and/or reporting. |
E&SSG has many services that can help you obtain compliance in the areas you need or desire. Most of our services are “turn-key” in nature, therefore, allowing you time to be more productive in your area of expertise.
|If required by the report findings pertaining to SARA Title III, sections 301-313 reporting, E&SSG will prepare and file your required Federal, State and Local reports as follows: |
1) Tier II Reporting – Just an additional $50/facility filing fee with this service.
2) Toxic Release Inventory (TRI) (AKA-Form R/A) – Quoted separately
|Coming Soon ||E&SSG will provide you secure access to your chemical inventory online via E&SSG's Compliance Watch Dog. This will allow CIA users to view the above up-to-date reports, and much more, as their inventory changes. |
* Results are subject to demand and response time from the client.
** Based on your preference.
***This is a basic Total Chemical Inventory report that will list just the MSDS Number, Product Name and Manufacturer, and Maximum Pounds (if given).