EPCRA Audits – Various U.S. Locations

EHS Support assisted a recreation facility management company with locations throughout the United States. The company provides day-to-day management of fitness and recreational facilities, including hiring, payroll, insurance, operations, marketing and sales, and programing and procurement.

EHS Support was retained to assist with auditing and reporting in compliance with the requirements of Sections 311 and 312 of the Emergency Planning and Community Right-To-Know Act (EPCRA) at 28 facilities throughout the United States. The operations included ice-skating rinks, athletic, fitness, and other related recreational facilities. Such operations often require the use of chemicals (i.e., ammonia and sulfuric acid) that, in certain quantities, trigger reporting requirements under EPCRA.

EHS Support identified the EPCRA requirements for each facility location. The findings were then compiled in a spreadsheet for easy reference when conducting interviews and developing and submitting annual chemical inventory (Tier II) reports.

Our environmental compliance professionals conducted in-person site visits at selected facilities, familiarizing themselves with the operations, types of chemicals used, and quantities of chemicals being used. A site-visit questionnaire was co-developed by EHS Support and a law firm in advance of the visits and was used by the assessors to identify facility contacts, facility characteristics, chemical types and quantities stored on-site, as well as record-keeping practices, previous Tier II reporting, and any past compliance issues.

During the site visits, EHS Support interviewed facility personnel, inspected each facility – focusing on chemical usage and storage – and compiled pertinent documentation. Based on the information gathered at the initial site visits, we developed a second questionnaire for conducting follow-up telephone interviews with general managers at the remaining facilities.

Upon compiling the information, EHS Support was able to identify reportable quantities of chemicals at each site. The audit revealed that 11 facilities stored chemicals at or above the reporting thresholds during the prior reporting year. Based on this finding, we completed Tier II reporting for those facilities. The entire process was documented in an EPCRA compliance audit report provided to the client, which included Tier II report submission timeframes, a summary of regulatory compliance research findings and reporting responsibilities, Tier II report submissions, and additional recommendations and best practices related to chemical management and record keeping.

The EPCRA audits were completed on time, and the Tier II reports were submitted before the March 1 reporting deadline. EHS Support’s audit report is the foundation for the client’s EPCRA program and will provide the client with the tools needed to complete future reporting.

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