EPCRA 312 Tier II Maximum Number of Occupants for Part-Time Occupied Facilities

On July 13, 2012 (77 FR 41300), EPA added fields to the EPCRA Tier II form that require the owner or operator to indicate whether the facility is manned or unmanned and the maximum number of occupants present at the facility at any one time. How should facilities that are only occupied part-time report for these fields?

Facilities that are manned at least part of the day should check the box “manned” and indicate the maximum number of occupants that may be present at any one time at the facility. Facilities such as convention centers, theaters, stadiums, or other large gathering places would already know the maximum number of occupants that may be present at any one time. Contractors, vendors, employees, and people that may be present for any training or other events should be included in the maximum number of occupants. Facilities that are never manned should check the box “unmanned” and check N/A on the Tier II form or enter 0 in the Tier2 Submit software for the maximum number of occupants. This information is useful for state and local emergency planners and responders and for planning evacuations during an emergency.

Additional guidance for completing the new fields can be found in the Instructions for EPCRA Tier II Form.