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Regulatory Information

Stop 15: Warehouse

Highlighted Topic:  Emergency Planning Requirements

Tour Stop 15If you have sufficient quantities of chemicals on site – even if they are just sitting in your warehouse and storage tanks – you will be subject to a series of interwoven requirements related to emergency planning and community right to know. Indeed, this may be one of your biggest responsibilities in regulatory compliance.

There are two general parts to these emergency planning requirements:

  • you must provide information to the authorities and to your local community regarding the materials you have on site, and
  • you must plan against accidental releases.

To meet these requirements, you will need to provide your storage tanks with such features as containment, corrosion protection, labeling, venting, and other preventive management measures.  You will also need to protect against spills and leaks during transfer and loading operations.

Several laws require emergency planning and community right to know for various lists of chemicals:

  • EPCRA, the Emergency Planning and Community Right to Know Act requires: 1) notification of authorities if you possess certain listed extremely hazardous chemicals, 2) notification if you have accidental releases, and 3) annual emissions reports – called the TRI (Toxic Release Inventory) reports.
  • The Clean Air Act requires planning for the accidental release of certain listed air toxics, known as "Risk Management Planning" or RMP requirements. Facilities covered under the requirement must develop a Chemical Accidental Release Prevention Program, including a hazards analysis and a Risk Management Plan.
  • The Clean Water Act requires a SPCC (Spill Prevention Control and Countermeasures) plan for any oil or hazardous materials storage that might release into surface waters.
  • OSHA has certain hazardous materials notification previsions. OSHA is not generally covered in this Handbook, but associated OSHA planning requirements include: 1) Hazardous Communication (Worker Right-to-Know), 2) the Process Safety Management (PSN) emergency action plan, and 3) the hazardous waste operations and emergency response planning requirements.
  •  Finally, there may be additional state and/or local notification or planning requirements that you will be subject to.

Other Regulatory Issues:

Remember that storage areas can be a source of fugitive air emissions that would need to be counted as part of your overall air source and managed.