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Question Number: 46, 1998 EPCRA 313 Q&A: Owner/Operator; Reporting Responsibility

46. Is the owner or the operator of a covered facility responsible for reporting?
Both the owner and the operator are subject to the Section 313 reporting requirements. If no reports are received from a covered facility both persons are liable for penalties, provided that the facility was required to file a Form R or the Alternative Certification Statement (Form A). As a practical matter, EPA believes that the operator is more likely to have the information necessary for reporting.