From: Debra Jacobson (firstname.lastname@example.org)
Date: Tue, 17 Feb 2004 13:39:15
Deadlines for SARA Title III Section 311 MSDS Reporting
According to 40 CFR 370.20(c), the owner or operator of a facility that is subject to Section 311 of SARA Title III must submit either all applicable MSDSs or list of hazardous chemicals that includes specific information. This submission is required for any hazardous chemical present at the facility at any one time in an amount equal to or greater than its threshold planning quantity (TPQ). The MSDS copies or chemical list must be submitted to the state emergency response commission (SERC) and the local emergency planning committee (LEPC) with jurisdiction over the reporting facility.
The initial deadline for reporting under this section was October 17, 1990. Additionally, facilities must comply with this requirement within three months after a chemical first triggers its applicable threshold amount.
The way that some facilities ensure continued compliance with this "update" type of requirement is by submitting a list of reportable chemicals (including the identification of the applicable hazard categories) on a quarterly basis to their SERC and their LEPC.
Source: "reg of the day" listserv operated by Tammy Silverthorne @ the Environmental Resource Center