E2 plans: what triggers one and what it must cover

The two tests

A regulated substance appears on the schedule with a threshold quantity. You are captured if you have that substance at or above the threshold, or if the container holding it has capacity at or above the specified level. Either test can catch you on its own, which surprises operators who look only at what is currently in the tank.

It is a two stage obligation

First comes a notice identifying the substances you hold. Then the plan itself. Both carry deadlines, and they are separate filings. Missing the notice while working on the plan is still non-compliance.

• ▸Inventory every substance on site, including intermediates and waste streams
• ▸Compare against the schedule on both quantity and container capacity
• ▸File the notice of substances within the required period
• ▸Prepare, test and keep the plan current after that

What the plan has to address

The plan must identify the substances and their hazards, the people and equipment available to respond, the measures to prevent an environmental emergency, and the steps to repair or restore the environment if one occurs. It also has to consider consequences beyond the fence line: who is downstream, downwind, and who would need to be notified.

Testing and review

Plans must be tested and reviewed on a cycle. In practice, testing is where the weaknesses surface: notification trees that are out of date, roles that were assigned to people who have left, equipment assumed available that is not. Treat the exercise as the point of the plan rather than an obligation attached to it.

Where we fit

We screen your substance inventory against the schedule, tell you plainly what is triggered and what is not, prepare the notice and the plan, and run the exercises that keep it credible.