94    SARA SECTION 313 REPORTING: BETTER THE SECOND
TIME AROUND?
John A. Lytle, Chemical Engineer
Katherine E. Imbrock, Environmental Coordinator
Burgess & Niple, Limited
Columbus, Ohio 43220
INTRODUCTION
The Superfund Amendments and Reauthorization Act of 1986' (SARA), in addition to amending
"Superfund" (the Comprehensive Environmental Response Compensation and Liability Act [CERCLA]), also established a separate, freestanding statute, the Emergency Planning and Community
Right-to-Know Act (EPCRA). EPCRA's provisions are contained in Title III of SARA (SARA
Sections 300 through 330).
EPCRA was enacted by Congress largely in response to the Bhopal, India disaster in which an
accidental release of methyl isocyanate from a Union Carbide-owned facility killed thousands of
Indian workers and nearby residents. The two main goals of the statute are: 1) to develop an
emergency planning infrastructure capable of effectively preventing and responding to accidental
releases of extremely hazardous chemicals at the community level; and 2) to make available to the
general public information on the toxic chemicals present in their communities.
Sections 311,312, and 313 of EPCRA established certain reporting requirements applicable to most
industrial facilities.2,3,4 The U.S. Environmental Protection Agency, in conjunction with state and
local agencies, is responsible for administering EPCRA's provisions. Figure 1 summarizes the division
of these responsibilities.5
Section 311 requires all facilities obliged to develop Material Safety Data Sheets (MSDSs) under the
Occupational Safety and Health Administration's (OSHA's) Hazard Communication Standard (29
CFR 1910.1200) to submit these MSDSs or an equivalent list of covered chemicals to their Local
Environmental Planning Committee (LEPC), State Emergency Response Commission (SERC), and
local fire department. LEPCs and SERCs are emergency planning entities provided for under Section
301 of EPCRA. Section 311 reporting is a one time reporting requirement. Subject facilities in
Figure 1.    Major responsibilities under Title III.
44th Purdue Industrial Waste Conference Proceedings, © 1990 Lewis Publishers, Inc., Chelsea, Michigan 481 If
Printed in U.S.A.
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