The Immense Cost of Duplicating EPCRA Compliance Efforts at State and Local Government Levels

Facilities must submit hazardous chemical inventory reports to the SERC, LEPC, and local fire department. Emergency planning notifications must be submitted to the SERC and LEPC. In areas where separate submittals are made to the state and local level, data management and compliance must be done at various levels.

This is an example of costly duplication of effort.

Outreach efforts most probably also overlap. Extra effort must be undertaken to ensure all reports received in one location have also been submitted to and received by the others. Both levels may be expending resources reviewing the same reports for the same issues, with unnecessary, redundant follow-up on individual facility issues. And both the state and local levels need to allocate resources to understanding and staying current on all the details and nuances of the reporting requirements and ever evolving EPA interpretations. The one-stop reporting approach, with one submittal sent to a central system where SERCs, LEPCs, and Fire Departments can all access the reports, is easier for businesses, SERCs, LEPCs, Fire Departments, and other involved parties than sending reports to multiple locations. But the advantages of a Hazconnect system for businesses go far beyond one-stop reporting.

Implementing a centralized online reporting system helps establish clear levels of responsibility for compliance. The centralized system allows immediate access to the facility reports by all levels of government. If compliance efforts are primarily handled through the state, LEPCs can focus on preparation and maintenance of emergency response plans and local community interaction. LEPCs can then be called upon when compliance issues require local knowledge and local follow-up, such as a site visit. This division of responsibilities makes it easier for businesses to understand who is responsible for what, therefore increasing the opportunity for accurate reporting and emergency planning. Moreover, Hazconnect provides flexibility if your State dictates more local responsibility. For example, compliance or notifications at the state level can be set at the local level if need be. So regardless how responsibilities are assigned, the system promotes coordination and effective use of resources across all levels of government without effort duplication.

In fact, the Hazconnect system was the pioneer advancing the one-stop shop approach over 20 years ago. Companies with facilities in multiple states that use Hazconnect (also known as TIER II MANAGER) have commented that they wish all states used the same system to simplify and strengthen compliance efforts and emergency planning, even across state boundaries.

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