Must a notifier submit a follow-up emergency notice after the initial 911 report?

In the event of a release of an extremely hazardous substance (EHS) or a CERCLA hazardous substance above its reportable quantity (RQ), a facility owner/operator must immediately notify the State Emergency Response Commission (SERC) and Local Emergency Planning Committee (LEPC) of the incident (section 304(b); 40 CFR §355.42) and for CERCLA hazardous substances, the National Response Center (NRC).

As soon as practicable after the release occurs, the facility owner/operator must submit a written follow-up emergency notice to the SERC and LEPC (section 304(c); 40 CFR §355.40(b)).  In the case of a release that occurs during transportation or storage incident to transportation, section 304(b) states that the emergency release notification requirements may be satisfied by providing notice to the 911 operator instead of the SERC and LEPC (40 CFR §355.42(b)).

Notification of a release during transportation or storage incident to transportation, including the requirement to submit a written follow-up notice, is satisfied by dialing 911 and providing the release information as described in 40 CFR §355.42 to the operator.  In the absence of a 911 number, the notifier may call the local operator to satisfy the emergency release notification requirements (section 304(b)(1)).