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Changes in Kentucky SARA Title III Emergency Plans
WRITTEN BYPatricia A. Mason, P.E.
If you aren’t already aware, be on the lookout for changes in Kentucky’s emergency response plans. Tab Q-7 plans are being transitioned to EHS Facility Emergency Response Plans. There is also a form “Facility Annual Certification Letter (FACL)” which will be due annually March 1, beginning in 2018. A DRAFT guidance for facilities DRAFT Emergency Response Planning Guide for EHS Facilities Self-Study Guide is available online. For more details regarding changes to Emergency Planning and Community Right-to-Know Act (EPCRA) Sections 302 and 303 emergency response plans, see my article posted on SMG’s website.
A local company engaged in manufacturing imported a small amount of a chemical substance defined under TSCA. Faced with a potential EPA enforcement action with penalties assessed for noncompliance under TSCA of up to $32,500 per day per violation, the company called SMG for help.
SMG analyzed the company’s current TSCA procedures and assisted the company in developing a proactive, cost-effective compliance procedure. SMG also facilitated a training program to educate employees about TSCA.
SMG worked with the company to develop mechanisms that assured adherence with the policies that were being implemented for compliance. Procedures to promptly correct any potential violations and prevent future violations were also put into place.
SMG was able to show that the company complied with the relevant TSCA regulations and was improving their TSCA policies and procedures to assure that future issues were less likely to occur. The company was not subjected to the proposed penalties and now has mechanisms in place to maintain TSCA compliance.