If you store extremely hazardous chemicals (EHS) equal to or in excess of established thresholds, you must provide chemical hazard information to local and state emergency response agencies annually.
For amounts above the reporting threshold, you must notify the State Emergency Response Commission (SERC) and Local Emergency Response Committee (LEPC) within 60 days.
For each extremely hazardous chemical exceeding the limits, the facility must:
- Prepare and submit an annual Tier II hazardous chemical inventory form to the State Emergency Response Commission
- Prepare and submit either copies of MSDS or a list of hazardous chemicals to the State Emergency Response Commission within 60 days of exceeding TPQ (Section 311)
- In New York City, prepare and submit a Risk Management Plan to the Local Emergency Planning Commission (New York City Department of Environmental Protection)
Risk Management Plan Requirements
The New York City Community Right-to-Know Law requires such facilities to develop and implement a Risk Management Plan.
The purpose of the plan is to protect surrounding communities, workers and emergency response personnel from the dangers associated with hazardous substances, extremely hazardous substances and resulting toxic substances by mitigating any harm they might pose.
To compile a Risk Management Plan for you, we will perform the following:
- On-site survey, with emphasis on acid storage areas, the HVAC system and air intakes and exhausts
- Survey surrounding areas to locate sewer inlets, hydrants, electrical manholes, subway entrances and similar features
- Prepare the NYC Extremely Hazardous Substance/Regulated Toxic Substance Report
- Develop specific programs for Risk Assessment; Risk Reduction and Emergency Response
- An initial safety audit of the acid storage facilities
- Identify and tabulate “public institutions” (as defined by the RMP regulations) within a half-mile of the facility, for inclusion in the report
- Prepare a comprehensive RMP Report, suitable for submission to NYC DEP
- Prepare appropriate diagrams for inclusion in the RMP Report
- All work will be performed by a licensed New York State Professional Engineer