['CERCLA, SARA, EPCRA']

['Release Notifications', 'SARA Compliance', 'Toxic/Hazardous Substance Releases', 'CERCLA, SARA, EPCRA']

09/28/2025

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How are notifications handled when a contractor brings extremely hazardous substances (EHSs) onsite over the threshold planning quantity or causes a reportable quantity release of an EHS?

...

How are notifications handled when a contractor brings extremely hazardous substances (EHSs) onsite over the threshold planning quantity or causes a reportable quantity release of an EHS?

RegSense Toxic/Hazardous Substance Releases CERCLA, SARA, EPCRA CERCLA, SARA, EPCRA SARA Compliance Release Notifications Environmental Protection Agency (EPA)Best Results FAQ Environmental English SARA Compliance Focus Area USA

For both sections 302 and 304 of the Emergency Planning and Community Right-to-Know Act (EPCRA), a contractor could be considered an operator of the facility or of a portion of the facility depending on if the contractor has enough authority. Neither the statute nor the regulations at 40 CFR 355 define operator.

If the contractor is considered an "operator," the contractor could be held liable for not making the required notifications under sections 302 or 304. If no notification is made under sections 302 and 304, the owner AND operator will be held liable.

['CERCLA, SARA, EPCRA']

['Release Notifications', 'SARA Compliance', 'Toxic/Hazardous Substance Releases', 'CERCLA, SARA, EPCRA']

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