I'm curious as to whether or not hazardous chemicals present in cars, trucks, forklifts, and other vehicles need to be considered for EPCRA Sections 311 and 312 reporting as present in the facility?

Enviro-fem,

From my reading of the regulation there do not appear to be any exclusions for the release from vehicles. However, I don't think the average vehicle could release a reportable quantity of hazardous substance.

Benzene has an RQ of 10 pounds. The concentration of benzene is somewhere around 700 ppm depending upon the blend. To release that 10 pounds to the environment you would have to spill more than 15000 pounds of fuel.

Just curious, is there over riding concern?

MikeCJ

Hi Mike,

You answered my concern. I was not certain if the vehicles release a reportable quantity. I think probably not. We had an issue with a delivery vehicle, but my understanding is that these are not considered present at the facility.

AE

I agree

enviro_fem:

I'm curious as to whether or not hazardous chemicals present in cars, trucks, forklifts, and other vehicles need to be considered for EPCRA Sections 311 and 312 reporting as present in the facility?

 According to the reg's.

 

EPCRA requirements do not apply to materials being transported. Therefore, materials being distributed or stored incidental to transportation (i.e., under active shipping papers) would not be included in a facility threshold determination under Sections 311 and 312.   However, spill reporting requirements under Section 304 would still apply to all materials, whether in transit or not.

 

You say you had an incident with a delivery vehicle but did not go into detail as to what the problem was, was the vehicle carrying an actual product being delivered? If so then it appears it does not need to be counted as per the reg listed above. If it was anything that stays permanently in the vehicle it may fall under 173.6 of the DOT book under Materials of trade exceptions.