SARA Regulations and
NCASI Handbook
PAPR 3531
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SARA Title III = EPCRA
SARA
= Superfund Amendments and
Reauthorization Act
EPCRA = Emergency Planning and Community
Right-to-Know Act
Public Law 99-499 Oct. 17, 1986
(35 pages)
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Superfund (CERCLA)
The Comprehensive Environmental Response, Compensation,
and Liability Act (CERCLA), commonly known as
Superfund, was enacted by Congress on Dec.11, 1980
Provided broad Federal authority to EPA to respond directly to
releases or threatened releases of hazardous substances that
may endanger public health or the environment. Specifically:
• Established prohibitions and requirements concerning closed
and abandoned chemically hazardous sites
• Provided for liability of persons responsible for releases of
hazardous substances at these sites
• Established a trust fund to provide for cleanup when no
responsible party could be identified
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SARA Title III
Purpose
• Enhance governmental planning and response to
chemical emergencies
• Facilitate governmental and public access to
information about chemicals used at and released
from facilities
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SARA Title III
Sections 301 to 303: Emergency Planning
• Local governments are required to prepare chemical
emergency response plans
• State governments are required to oversee and
coordinate local planning efforts
• Facilities with Extremely Hazardous Substances (EHSs)
on-site in quantities greater than Threshold Planning
Quantities (TPQs) must cooperate in emergency plan
preparation
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SARA Title III
Section 304: Emergency Notification
• Facilities must immediately (orally) report accidental
releases of EHSs and hazardous substances* in
quantities greater than corresponding Reportable
Quantities (RQs) to state and local officials
• A written follow-up report must be submitted to state
and local officials
• Information about accidental chemical releases must be
available to the public
* Defined under the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA or “Superfund”)
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SARA Title III
Sections 311 and 312: Community Right-to-Know
• Facilities manufacturing, processing, or storing designated
hazardous chemicals* must submit their Material Safety Data
Sheets (MSDSs), or a detailed MSDS list, to state and local
officials and local fire departments
• Facilities must also report annually, to state and local officials and
local fire departments, inventories of all on-site chemicals for
which MSDSs exist
• Information about chemical inventories at facilities and MSDSs
must be available to the public
* Chemicals defined under OSHA's Hazard
Communication Standard as requiring an MSDS
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SARA Title III
Section 313: Toxics Release Inventory (TRI)
• Facilities must complete and submit a Toxic
Chemical Release Inventory Form annually for each
of the Toxic Release Inventory (TRI) chemicals that
are manufactured, processed, or otherwise used
above applicable threshold quantities.
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SARA 313 (TRI) Chemicals
• The TRI chemical list includes over 600 substances
• Chemicals on the list change periodically (e.g.,
added, removed or modified)
• On November 26, 2010, EPA finalized a rule adding
16 chemicals “reasonably anticipated” to be human
carcinogens to the TRI list
• For each reportable chemical, a “Form R” (6-page
form) must be completed and submitted to USEPA
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SARA Chemical List:
Example - Those with Qualifiers
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SARA 313 Form R Information
• Basic facility information
• Identity of the toxic chemical
• Activities involving, or uses of, the chemical at the facility
◦ Manufactured (e.g., as a product, byproduct, or impurity)
◦ Processed (e.g., as a reactant, component, or impurity)
◦ Otherwise used (e.g., as a chemical processing aid or
manufacturing aid)
• Maximum amount of chemical onsite during the reporting year
• Amounts of the chemical entering environmental media onsite (air,
water, land) for the year
• Amounts of the chemical transferred offsite for the year
◦ POTWs (municipal WWTPs)
◦ Other (e.g., commercial landfill)
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SARA 313 Form R Information
• Onsite energy-recovery processes involving the chemical
• Onsite recycling processes involving the chemical
• Amounts of the chemical involved in source reduction,
energy-recovery, and recycling activities
• Amount of the chemical released into the environment from
remedial actions, catastrophic events, or one-time events not
associated with production processes
• NOTE: A 2-page “Form A” certification can be submitted for a chemical
instead if (1) the amount manufactured, processed or otherwise used is no
more than 1,000,000 pounds/yr and (2) the “annual total amount” (ARA)
for the chemical does not exceed 500 pounds. The ARA is equal to the
combined total amounts released or disposed onsite, treated onsite,
recovered onsite by recycling, and combusted onsite for energy recovery,
plus the amounts transferred from the facility to off-site locations for
recycling, energy recovery, treatment, and/or disposal. Does not apply to
most PBTs.
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SARA 313 Facilities
What facilities have to report?
• The facility has 10 or more full-time employee
equivalents
• The facility is included in a North American
Industry Classification System code as designated
by USEPA
• The facility manufactures (including imports),
processes, or otherwise uses any SARA 313
chemical in quantities greater than the established
threshold during a calendar year
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SARA 313 Reporting Thresholds
The per-chemical thresholds that trigger
reporting
•
•
•
•
Manufacturing: 25,000 lbs/yr,
Processing: 25,000 lbs/yr, or
Otherwise use: 10,000 lbs/yr
Thresholds for designated PBT (Persistent,
Bioaccumulative, Toxic) chemicals are much
lower
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SARA 313 Definitions
Manufacture:
• The term “manufacture” means to produce,
prepare, compound, or import a SARA 313
chemical
• It includes coincidental production (e.g., as a
byproduct or impurity) as a result of the
manufacture, processing, otherwise use or
disposal of another chemical or mixture of
chemicals
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SARA 313 Definitions
Process:
• The term “process” means the preparation of
a SARA 313 chemical, after its manufacture,
for distribution in commerce
• Processing is usually the incorporation of a
chemical into a product
• A facility may process an impurity that
already exists in a raw material by
distributing that impurity in commerce
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SARA 313 Definitions
Otherwise use:
• The term “otherwise use” means any use of a
SARA 313 chemical, including a chemical
contained in a mixture or other trade name
product or waste, that is not covered by the
terms manufacture or process. It includes use
as a processing or manufacturing aid.
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NCASI SARA 313 Handbook
Provides general information and industry-specific
guidance for three segments of the forest products
industry:
• Pulp and paper mills (esp. kraft pulp mills)
• Recycling and non-integrated paper mills
• Wood products facilities
Handbook is updated every year to include any:
• Changes to the regulations
• New guidance on the regulations
• New data* to help in performing calculations
*SARA does not require a facility to have site-specific measurements
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NCASI SARA 313 Handbook
The handbook contains:
• A compilation of regulatory background
information (guidance, regulations, and
forms)
• Chemical-specific “sheets” (information) for
about 90 listed chemicals or chemical
categories of greatest relevance to the forest
products industry
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NCASI SARA 313 Handbook
Example Chemical Sheet Excerpts: Methanol
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