Both the owner and the operator are subject to the Section 313 reporting requirements. If no reports are received from a covered facility, both persons are liable for penalties, provided that the facility was required to file a Form R or the Alternative Certification Statement (Form A). As a practical matter, EPA believes that the operator is more likely to have the information necessary for reporting. Additional information on reporting responsibilities can be found in the Revised 1998 EPCRA Section 313 Questions and Answers Document.
Is the owner or the operator of a covered facility responsible for reporting?
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