On October 16th, 1986 the Superfund Amendment Reauthorization Act, also known as SARA was signed into law.  Title III of this law is known as Community Right-to-Know which gives emergency responders and community members the ability to find out what hazards are in their area.  Prior knowledge of what chemicals are present and what effects they may have allow community leaders and emergency responders to conduct emergency planning.  Emergency planning can cut the time needed to respond to a chemical emergency and speed up containment and clean-up.  With faster containment and clean-up environmental damage is decreased along with the cost associated with a chemical incident.

When a EHS is part of a mixture, ONLY THE EHS PART OF THE MIXTURE IS COUNTED TOWARD REPORTING REQUIREMENTS.  For example, if you have a product that is 50% ammonia, which has a TPQ of 500 pounds, you must have 1,000 pounds or more of the product on hand before you have to report.  Mixture and percentage information can be obtained from the product label or the Material Safety Data Sheet (MSDS).  If you can not obtain the mixture percentage from the label or the MSDS, contact the manufacturer or report the mixture as a whole.

A MSDS will list chemicals in two ways, either as a Hazardous Substance or an Extremely Hazardous Substance.  A Hazardous Substance is defined by the Occupational Safety and Health Act (OSHA) under the Hazardous Communication Standard (HCS).  HCS requires employers to maintain MSDS's available under the Employee Right-to-Know requirements.  Hazardous Substance classifications are constantly changing and there are an estimated 50,000 substances at this time.  For a listing of Extremely Hazardous Substances we have provided a link to EPA's List of lists document.   This document is provided to you in Adobe Acrobat format

To provide notification to the LEPC and the MDE that the facility is subject to the planning requirements under Section 302, simply write a letter to:

Harford County Government
Division of Emergency Operations
2220 Ady Road
Forest Hill, Maryland  21050

Maryland Department of the Environment
Community Right-To-Know, Section 302
2500 Broening Highway
Baltimore, Maryland  21224

Refer to Appendix A of the "The Right-to-Know, A Guide for Business" for instructions on how to prepare and information to include in this letter. 

This information is provided in Adobe Acrobat format.  You may obtain a free copy of the Adobe Reader at www.adobe.com/prodindex/acrobat/readstep.html.

This is not a yearly report, the only other time you must re-contact the LEPC and the MDE is if an EHS chemical is added to or deleted from inventory.   All changes should be reported within sixty (60) days of the addition or deletion.

In the 302 notification you must designate a coordinator to work with the LEPC and provide facility information when needed.  Facility coordinators are encouraged to attend all Harford County Local Emergency Planning Committee meetings.   Meetings are normally held on the third Wednesday of each month at 3:00 p.m.   Please call 410-638-4900 for additional information on LEPC meetings.

Farm facilities are not required to develop emergency response plans for their facilities under the current requirements of SARA Title III.   However, they may be required by your insurance company or other OSHA regulations.   If you require any assistance in preparing a plan, please call 410-638-4900.

Sara Title III, Section 304, covers emergency notification requirements when there is a release into the environment of any Hazardous or Extremely Hazardous Substance over the designated Reportable Quantity (RQ).   If there is any danger of off site exposure YOU MUST REPORT THE INCIDENT.

When the amount of spillage is at or greater than the listed RQ and off site exposure has, or has the potential to occur, you are required to start reporting procedures under Section 304.

The release of a pesticide registered under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), when used generally in accordance with its intended routine agricultural applications, according to approved product label instructions, is exempt from this reporting requirement, and also normal application of fertilizers.  This exemption applies ONLY TO ON SITE RELEASES.

When a covered release has occurred, YOU ARE REQUIRED TO CONTACT THE HARFORD COUNTY DIVISION OF EMERGENCY OPERATIONS IMMEDIATELY.  THE EMERGENCY NUMBER 911 SHOULD ALWAYS BE USED FOR THIS PURPOSE.  BE PREPARED TO GIVE THE FOLLOWING INFORMATION:

1. Name of chemical released.
2. If the chemical is a listed EHS.
3. Quantity released.
4. Date, time and duration of release.
5. Your name.
6. Environmental media affected (soil, air, or water).
7. Location of the release.
8. Number of injured or ill personnel, if any.
9. Number of contaminated personnel, if any.

DO NOT DELAY REPORTING AN INCIDENT:
TO PREPARE OR RESEARCH INFORMATION

If the release has the potential to cause illness, injury or damage on site or off site, do not hesitate to ask for assistance.  Immediate on site response to a hazardous materials incident, to prevent possible off site problems, is good but should not be done with untrained people who may be killed, seriously injured or subject to health risks. 

The National Response Center will have to be notified of the covered release.  After the incident is under control, a written report has to be submitted to the LEPC and MDE and the National Response Center.  This report should include:

1. Name of chemical released
2. If the chemical is a listed EHS
3. Quantity of chemical released
4. Date, time and duration of release
5. Person who provided initial verbal notification to the National Response Center
6. Identification of the environmental media into which the release occurred
7. Health risks (know or anticipated acute or chronic risks associated with the release)
8. Medical attention and information availability
9. Precautions that were taken to prevent a reoccurrence of a similar release
10. Further information that is relevant to the chemical release

If a fire should occur in an on site farm or co-op storage containing EHS or hazardous chemicals, it can be reportable under Section 304.  It is wise to submit a site plan to notify emergency responders of storage locations.  If a storage area is involved in a fire, expect the firefighters to allow this fire to burn as hot as possible to consume the stored materials.  Notification of storage areas can eliminate any "guess work" by emergency responders and assist in fire suppression activities.

Under SARA Title III, Section 311 and 312, Chemical Inventory Reporting, any chemical used in routine agricultural activities is exempt from reporting.   If any inventory is maintained for non-agricultural uses, over the designated TPQ or 10,000 pounds, it must be reported to the Maryland Department of the Environment, the Harford County Local Emergency Planning Committee and the local fire department who responds to your facility.

For additional information on SARA Title III contact Harford County Division of Emergency Operations at 410-638-4900 or e-mail your request to mkmoses@co.ha.md.us.