Managing a Nationwide EPCRA Program

American Airlines operates in over 200 airports across the United States, which means all of these stations have the potential to meet reporting thresholds for EPCRA.    The federal reporting thresholds are 10,000 pounds for hazardous materials and 500 pounds for EHSs (in most cases), but like with many protocols different states have created stricter thresholds.  For example, Louisiana reporting thresholds are 500 pounds, Nevada thresholds are based on the Fire Code protocols, and New York City thresholds are based on a specific list of chemicals where all weights must be reported.  Of course, there are also specific California reporting thresholds.  In most cases, reporting must be completed between January 1 and March 1 every year.  With so many potentially reportable stations, American Airlines has devoted a full time position to ensure that any necessary reports are submitted on time and accurate.

This presentation aims to look at how American Airlines manages obtaining inventories from the stations, determining reporting requirements, completing reporting on time, and lessons learned.    We will also be discussing the merger process between American Airlines and US Airways and how that has impacted 2016 EPCRA Tier II Reporting.