If a facility purchases more than 10,000 pounds of a hazardous chemical for which OSHA requires an MSDS in a calendar year but never actually receives or stores more than the 10,000 pound threshold at one time, must the facility report under EPCRA Sections 311 and 312?

The MSDS and inventory reporting requirements under EPCRA Sections 311 and 312 are only for hazardous chemicals present at the facility at any one time in amounts equal to or greater than their thresholds. This reporting determination is not based on the amount of hazardous chemicals purchased, but rather how much was present at a facility.