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U.S. EPA…SARA, Section 304 (Emergency Spill & Release Notification)

Vanguard provides expert support to ensure your facility complies with emergency spill or release reporting requirements under Section 304 of the Superfund Amendments and Reauthorization Act (SARA).

If your facility inventories hazardous substances, you may be required to report any accidental release that meets or exceeds the Reportable Quantity (RQ) assigned to any chemical as designated within the current list of over 750 chemicals. Vanguard helps organizations and entities respond appropriately and legally to spills or releases, ensuring swift compliance and minimizing risk associated with enforcement penalties.

What Is SARA Section 304?

Section 304 of SARA Title III, also known as the Emergency Planning and Community Right-to-Know Act (EPCRA), requires that any facility spilling/releasing a hazardous substance above its Reportable Quantity (RQ) must immediately notify designated emergency response authorities.

The purpose of Section 304 is to protect public health, safety, and the environment by ensuring rapid notification of emergency incidents involving hazardous chemicals.

What Triggers a Section 304 Notification?

An emergency spill or release must be reported if it involves:

  • One or more of the 750+ hazardous substances listed under CERCLA and EPCRA at a quantity equal to or in excess of the Reportable Quantity (RQ) assigned to the substance spilled or released.
  • A release that leaves the facility’s legal boundaries (e.g., into the air, groundwater, stormwater systems, or off-site lands)
  • The release must be unplanned and not permitted under any existing air, water, or waste regulations.

Who Must Be Notified?

In the event of a qualifying release, the facility must immediately report the incident to:

  • The National Response Center (NRC) at 1-800-424-8802
  • The State Emergency Response Commission (SERC)
  • The Local Emergency Planning Committee (LEPC) having jurisdiction over the affected area

In some states, additional local or regional agencies may also require notification.

What Must Be Included in the Report?

The initial oral report must include:

  • Substance name(s) and estimate of quantity(ies) released
  • Time and duration of the release(s)
  • Media into which the release(s) occurred (air, water, land)
  • Health risks and medical advisory(ies) for exposed individuals, if known
  • Precautions taken to minimize health impacts and risks to the community-at-large
  • Contact information for the facility and responsible party

A written follow-up report (within 5 days) is typically required, summarizing the same details and describing any corrective actions taken.

Vanguard’s Emergency Release Compliance Services Include:

24/7 Incident Response Guidance

  • On-call experts to walk your team through immediate notification steps
  • Confirm whether your incident qualifies under SARA 304
  • Draft call scripts and follow-up messaging for NRC, SERC, and LEPC

Reportable Quantity (RQ) Screening

  • Review of spill quantity against RQ thresholds
  • Real-time assessment using Safety Data Sheet (SDS) data and inventory quantities
  • Coordination with your Environmental Management System (EMS) provided by Vanguard

Written Follow-Up Reports

  • Assistance with preparation of required documentation for agency submission
  • Summary of incident details, impact analysis, and mitigation measures
  • Assistance with filing to NRC, SERC, and LEPCs, and other regulatory bodies as required

Root Cause Investigation & Documentation

  • Spill incident reviews to prevent recurrence
  • Advisory for root cause analysis and corrective action planning
  • Future planning for your facility’s compliance tracking system

Emergency Response Planning Support

  • Assistance with development of incident response protocols
  • Employee training on reporting procedures (provided in onsite OSHA HazCom Training)
  • Integration with SPCC and RCRA contingency plans, as needed

Why Section 304 Compliance Matters

  • Non-compliance can result in fines up to $71,546 per day, per violation
  • Failure to report can trigger EPA investigations, community complaints, citizen suits, and legal proceedings advanced by environmental watchdog groups
  • Prompt notification demonstrates responsible management and reduces long-term liability
  • Accurate documentation is essential for internal incident tracking, insurance, and audits

Industries Commonly Affected

  • Oil & Gas
  • Manufacturing & Processing
  • Chemical Storage & Transport
  • Food & Beverage
  • Utilities & Energy
  • Pharmaceuticals & Laboratories
  • Agriculture & Feed Mills

Why Vanguard?

  • Deep experience navigating multi-agency emergency reporting
  • Expertise in spill prevention and post-incident documentation
  • Familiar with state-specific follow-up requirements and timelines
  • Rapid response support integrated with your EMS
  • Trusted partner in regulatory compliance and environmental risk mitigation

Contact Vanguard for Emergency Spill & Release Compliance

Section 304 of SARA Title III requires facilities to report hazardous substance releases that exceed Reportable Quantities (RQ) to emergency authorities—immediately. Vanguard helps you comply with these urgent requirements by providing 24/7 incident response support, RQ screening, follow-up reporting, and root cause documentation. Call (918) 641-5588 or contact us today for expert guidance and to minimize your enforcement risk.

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