EPCRA: Toxic release reporting requirements and reductions for the department of defense

Abstract

Department of Defense (DOD) installations are required by Executive Order 13148 to comply with the Emergency Planning and Community Right-to-Know Act (EPCRA), achieve reductions in usage and releases of toxic chemicals, and implement other programs, such as environmental management systems and audits. EPCRA section 313 compliance requires each DOD installation to evaluate more than 600 chemicals for possible annual reporting to EPA and state regulators. Achieving these goals at the installation level is further complicated by EPA's ongoing modifications to the EPCRA requirements, and the differences between DOD and EPA guidance for the specific compliance actions that must be taken. In addition to describing the EPCRA requirements, available DOD guidance, and key compliance issues of importance to military installations, this article recommends approaches to resolving DOD/EPA guidance differences, and provides insight into the importance of the EPCRA data.