Release and other waste management quantities for the year prior to the reporting year must be entered in Sections 8.1-8.7, Column A of the Form R. Am I required to complete these sections for an EPCRA section 313 chemical whose manufacture, process, or other use did not exceed an applicable threshold at my facility in the prior reporting year?
Yes. You are required to complete Sections 8.1-8.7, Column A for each chemical for which you are required to submit a Form R report. In completing these Sections, you may use your best readily available data (or reasonable estimates if such data are not readily available). Facilities in a covered industry sector that manufacture, process, or otherwise use an EPCRA section 313 chemical are expected to retain any documentation that may be necessary for the purpose of developing estimates for these Sections.