Guidelines for SARA compliance

The initial deadline is past for SARA Title III (Section 313), but the job is not over. Section 313 is a continuing annual reporting regulatory program. EPA Form Rs for each SARA chemical must be submitted by July, and for each succeeding year the chemical exceeds the applicable threshold. Moreover, since chemical-use applicability thresholds decrease in 1989 and 1990, the scope of work could increase as the list of chemicals to be reported grows. As part of the compliance process, two inventories need to be completed. First a chemical inventory to determine that a Sec. 313 chemical is manufactured, processed, or otherwise used at the facility, and that quantities handled exceed an applicable threshold amount. Second, an inventory of toxic chemical releases to any of the three environmental (air, water or land) media and/or transfers to an off-site location.