EPA Makes Substantial Change to EPCRA Tier II Reporting Requirements for 2017
EPA did not go through notice and comment rulemaking for this action, claiming that the rule simply adopts the OSHA HCS hazard classes, so regulated facilities will only need to copy the information from their safety data sheets. Reporting under the new hazard categories begins with the next reporting deadline of March 1, 2018 for calendar year 2017 information.
Several NACD members have stated that this change will result in many additional hours of work for reporting facilities. NACD plans to express these concerns to EPA and to seek relief for members in the near future. If you have examples of how this change will impact your company’s reporting burden, please send them to Jennifer Gibson at firstname.lastname@example.org. Your input will help us to make our case to EPA.
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