How to write a chemical handling program for a small brewery

Last updated 2026-07-11

Why do small breweries need a chemical handling program?

Breweries run on hazardous chemicals, more than most owners realize. Caustic soda (sodium hydroxide) cleans fermenters. Peracetic acid sanitizes. CO2 carbonates and purges. Phosphoric acid adjusts pH. Chlorine-based sanitizers show up in even the smallest taproom. Some shops also run ammonia refrigeration, which drags in a whole separate layer of OSHA rules.

OSHA's Hazard Communication Standard, at 29 CFR 1910.1200, applies to any employer whose workers may be exposed to hazardous chemicals. That covers every brewery with at least one employee besides the owner. The standard requires a written hazard communication program, Safety Data Sheets (SDS) for every hazardous chemical on site, properly labeled containers, and training before a worker handles or is exposed to a covered chemical ^[1].

The stakes are real. Caustic cleaning solutions cause chemical burns. CO2 in an enclosed space displaces oxygen and can kill in minutes. Peracetic acid chews at the respiratory tract. The Bureau of Labor Statistics reports that chemical exposures account for a meaningful share of nonfatal occupational injuries in food and beverage manufacturing ^[2]. Small operations get hurt more, because there's usually no dedicated safety person and training happens on the fly.

Then there's the money. HazCom sits near the top of OSHA's most-cited standards year after year. A serious violation runs up to $16,131 under 2024 penalty levels ^[3]. A willful or repeated one tops $161,323. For a brewery running on thin margins, that math wakes you up.

What OSHA standards apply to brewery chemical handling?

The anchor is 29 CFR 1910.1200, the Hazard Communication Standard (HazCom 2012). It follows the Globally Harmonized System (GHS) of classification and labeling. Every brewery falls under this rule. Full stop.

Depending on your operation, other standards stack on top:

• CO2 and confined spaces. If workers enter fermenters, bright tanks, or any vessel where CO2 can collect, 29 CFR 1910.146 (Permit-Required Confined Spaces) kicks in. CO2 is heavier than air and pools at floor level and in low points. It's one of the most underappreciated hazards in craft brewing ^[4].
• Ammonia refrigeration. Breweries with anhydrous ammonia systems holding 10,000 pounds or more trigger OSHA's Process Safety Management standard at 29 CFR 1910.119 and EPA's Risk Management Program ^[9]. Most small shops don't hit this, but if you're scaling, learn the number now.
• Lockout/Tagout. When workers clean or service equipment holding chemical residue, lockout tagout procedures under 29 CFR 1910.147 apply. A fermenter that wasn't properly isolated can still hold caustic.
• Personal Protective Equipment. 29 CFR 1910.132 through 1910.138 covers PPE selection, provision, and training. What you need for caustic is not what you need for peracetic acid, and OSHA requires you to document the hazard assessment behind your choices ^[5].
• Emergency Action Plan. 29 CFR 1910.38 requires a written emergency action plan for breweries with more than 10 employees. Under that, you still need a plan, but you can deliver it orally.

If your state runs its own OSHA-approved plan (California, Washington, Michigan, and roughly two dozen others), the state rules apply instead of the federal ones. State plans must be at least as effective as federal standards, and some go further ^[6].

What chemicals do breweries actually need to track?

Walk your whole facility with a clipboard and write down every chemical product you buy, store, or use. Cleaning products, sanitizers, lab reagents, boiler chemicals, refrigerants, CO2 cylinders, lubricants, and whatever sits in your water treatment system. Miss nothing.

Common brewery chemicals that need SDS documentation:

Chemical	Typical Use	Key Hazard
Sodium hydroxide (caustic soda)	CIP cleaning	Severe skin/eye burns
Peracetic acid (PAA)	Sanitizing	Respiratory irritant, corrosive
Phosphoric acid	pH adjustment	Corrosive
Sodium hypochlorite (bleach)	Sanitizing	Chlorine gas risk if mixed with acid
Hydrogen peroxide	Sanitizing	Oxidizer, irritant
CO2	Carbonation, purging	Asphyxiant
Ammonia (anhydrous or aqueous)	Refrigeration, cleaning	Toxic, corrosive
Potassium metabisulfite	Antioxidant, sanitizer	SO2 release, respiratory hazard
Iodophor (iodine sanitizer)	Sanitizing	Irritant
Boiler treatment chemicals	Varies	Varies by product

Once the list exists, pull the SDS for each product from the manufacturer. Under HazCom 2012, every SDS follows the same 16-section format. Section 2 gives you the hazard classification. Section 8 gives you exposure limits and required PPE. Section 14 covers transport. Keep a master list that ties each chemical to its SDS.

Check the hcl safety data sheet too, if you use hydrochloric acid for descaling or lab work. Smaller operations forget it all the time.

How do you structure the written hazard communication program?

OSHA requires the written HazCom program to spell out four things: how you identify hazardous chemicals, how you manage SDS documents, how you label containers, and how you train employees ^[1]. Your written document has to cover each one out loud. Here's a structure that works.

1. Scope and purpose. One short paragraph naming your facility, your program administrator, and what the program covers. Name a backup in case the primary is out.

2. Chemical inventory. This is the backbone. A table or spreadsheet listing every hazardous chemical by product name, common name, manufacturer, and where its SDS lives. Update it whenever you add or drop a product. OSHA doesn't mandate a format, but the list has to exist and be current.

3. Safety Data Sheet management. State where SDS documents live (a physical binder at a fixed spot plus a digital backup is smart), how workers get to them on every shift, and who chases down the SDS when a new chemical shows up. OSHA requires SDS to be accessible during the work shift, more than handed over on request ^[1].

4. Container labeling. Shipped containers keep their manufacturer labels. Any chemical you pour into a secondary container gets a label with the product name and the relevant hazard warnings. Fill a spray bottle with caustic cleaner that someone else might grab, and that bottle needs a label. Portable containers used immediately by the person who filled them are exempt, but "immediately" means the same shift and nothing longer.

5. Training. Describe the program: what you cover, when it happens (at hire, before a new chemical arrives), who delivers it, and how you document completion.

6. Non-routine tasks and contractor notification. Cover any infrequent task where chemical exposure could happen. If contractors come in, explain how you tell them about your chemical hazards.

7. Review and revision schedule. Commit to an annual review, plus a review any time the inventory or process changes in a real way.

If building this from scratch feels heavy, tools like SafetyFolio's program generator can spit out a compliant draft tailored to your chemical list in about 15 minutes, which you then read, correct, and sign.

What should brewery employee chemical safety training cover?

OSHA lays out what HazCom training must cover at 29 CFR 1910.1200(h). Handing someone an SDS and calling it done doesn't count.

Required training content:

• The physical and health hazards of the chemicals in the work area
• How to detect the presence or release of a hazardous chemical (odor, sight, monitoring)
• Steps workers can take to protect themselves, including PPE, work practices, and emergency procedures
• How to read and use an SDS
• The details of the written HazCom program, including where to find it and the SDS binder

Good brewery training goes past the paper. Show workers what caustic splash looks like, how to use an eyewash station, what to do when a CO2 alarm sounds, and how to respond to a peracetic acid spill. Follow classroom or computer instruction with a hands-on demonstration.

Timing is the part people miss. Training happens before the employee works with or near a hazardous chemical the first time. Add a new chemical to your process, and affected workers need training before they touch it. Retraining when processes change is not optional ^[1].

Document everything. Keep a record per employee: date of training, chemicals covered, and how you checked understanding. A sign-in sheet plus a short quiz holds up in an inspection. "I told them" does not.

For supervisors and leads who run chemical-handling tasks, OSHA 30 training builds a deeper foundation. It's no substitute for HazCom-specific training, but it gives leads the vocabulary to catch problems before they turn into incidents.

How do you handle SDS documents for a small brewery?

Every hazardous chemical on site needs a current SDS, and workers must reach it during their shift without asking a manager for permission. That's the practical test OSHA runs.

The simplest system for a small brewery is a three-ring binder in the production area (not locked in an office), organized alphabetically or by work area, with a printed index up front. Put a second binder in the taproom if taproom staff touch any chemicals, like glass cleaner or line cleaner.

Digital-only works, but only if a computer or tablet is always reachable on every shift, including nights and weekends. If your point-of-sale terminal is the only computer and it lives in the manager's office, that's not accessible. Plenty of small shops run a hybrid: a physical binder for daily chemicals, digital access for the full list.

Get the SDS before a new chemical arrives, not after. Most manufacturers post SDS documents on their websites. If a supplier can't or won't hand over an SDS for a product they call hazardous, that's the supplier's problem, and not something you can paper over.

Review your SDS documents on a schedule. GHS requires an SDS to be updated when new hazard information surfaces. A 10-year-old SDS for a product that changed formulation may not reflect what's actually in the bottle.

For your hazard communication program to survive an inspection, the SDS binder should match the chemical inventory list exactly. Inspectors routinely ask to see both, side by side.

What PPE is required for handling brewery chemicals?

OSHA requires a written hazard assessment to determine the PPE needed for each task involving chemical exposure, under 29 CFR 1910.132(d). The assessment gets certified in writing, with the date and the name of the person who did it ^[5].

For common brewery chemicals, here's a starting baseline. These aren't OSHA mandates. They're practical minimums you verify against your specific product SDS documents.

Chemical	Minimum PPE
Caustic soda (dilute, <5%)	Chemical splash goggles, rubber/nitrile gloves, apron
Caustic soda (concentrate, >5%)	Face shield + goggles, heavy rubber gloves, rubber apron, boots
Peracetic acid	Chemical splash goggles, nitrile gloves, apron; face shield for splashing operations
Phosphoric acid	Chemical splash goggles, nitrile gloves, apron
Sodium hypochlorite	Chemical splash goggles, nitrile gloves
CO2 (cylinder handling)	No special PPE for handling; asphyxiation monitoring for enclosed areas
Ammonia refrigerants	Requires full program; air-supplied respirator for emergencies

Nitrile isn't universal. Check the SDS chemical resistance section for your specific product and concentration. Some solvents degrade nitrile fast. If the SDS calls for butyl rubber gloves, that's what you buy.

Respiratory protection kicks in when engineering controls can't drop airborne exposures below the limit. Peracetic acid, for one, carries an OSHA ceiling of 0.4 ppm. If ventilation falls short during certain tasks, a respirator may be required, and that triggers a full respiratory protection program under 29 CFR 1910.134, including medical evaluations and fit testing.

Buying PPE is only half the job. You also train workers on when to use it, how to put it on and take it off, how to inspect it, and how to maintain or replace it ^[5].

How do you write a chemical spill response procedure for a brewery?

Spill response isn't its own OSHA standard for small breweries, but it feeds several: the emergency action plan (29 CFR 1910.38), HazCom training, and possibly RCRA or EPA reporting if the chemical reaches a floor drain tied to the municipal sewer.

A workable brewery spill procedure covers four things: containment, personal protection, cleanup, and reporting.

Containment. For most brewery cleaning chemicals, this means stopping the flow at the source (close the valve, right the tipped container), keeping the material out of floor drains, and stopping it from spreading. Secondary containment under chemical storage, a simple plastic-lined curb, is cheap and it works.

Personal protection. Anyone responding to the spill needs the right PPE for that chemical before they engage. If the SDS calls for a face shield and rubber apron, the responder wears both before touching anything. Post a quick-reference card at your PPE station: chemical name, required spill PPE, emergency action.

Cleanup. Most brewery chemicals are water-soluble and can be diluted and flushed after pH adjustment. But you need to know which ones need absorbent (some acids and bases react with certain absorbents), which throw heat when they hit water, and which can't go down the drain in your jurisdiction. Ask your local publicly owned treatment works (POTW) if you're unsure about drain discharge limits.

Reporting. For large spills of certain chemicals, CERCLA Section 103 and EPCRA Section 304 require immediate notification to the National Response Center once you release a reportable quantity. For ammonia, that's 100 pounds. Most small brewery cleaning spills won't hit these thresholds in one event, but know the rules before you need them.

Keep spill kits stocked and in known spots. A caustic or acid kit usually holds pH-neutral absorbent, a neutralizing agent, heavy-duty bags, and the right PPE. Inspect kits monthly and swap out used or degraded materials.

How do you address CO2 hazards specifically?

CO2 is the deadliest hazard most brewers treat as harmless. It kills. Between 2013 and 2018, brewery workers in the United States and Europe died from CO2 asphyxiation in fermentation areas and cellars. The gas is colorless, odorless, and builds up without a single warning sign ^[4].

OSHA has no CO2-specific standard, but several intersect. 29 CFR 1910.146 covers permit-required confined spaces, and any vessel with CO2 present qualifies if it meets the OSHA definition ^[8]. The atmospheric testing requirements alone, calibrated gas monitors checked by a competent person, get skipped constantly in small breweries.

Even in open areas like a cellar floor, CO2 pools to dangerous levels. OSHA's permissible exposure limit (PEL) for CO2 is 5,000 ppm (0.5%) as a time-weighted average. The NIOSH immediately dangerous to life or health (IDLH) value is 40,000 ppm ^[12]. At roughly 7 to 10 percent, CO2 drops a person unconscious in minutes.

Practical controls for small breweries:

• Install fixed CO2 monitors with audible and visual alarms in cellar areas and any room where CO2 is stored or used in quantity. Set the warning alarm at 1% (10,000 ppm).
• Never work alone in a cellar or fermentation room during active CO2 production without a monitor.
• Confirm mechanical ventilation is running before anyone enters. Don't assume it is.
• Put CO2 emergency response in your training. Workers need to know the rule: if the alarm sounds, you leave first and investigate after.

List CO2 as a chemical on your inventory. It has an SDS. Include it in HazCom training. It's not a plain utility gas. It's a regulated hazardous chemical that has killed people in rooms exactly like yours.

What recordkeeping does OSHA require for a brewery chemical program?

Recordkeeping separates a real program from a paper one that folds under inspection. Here's what to keep and for how long.

Written HazCom program. No expiration, but review it at least annually and any time your inventory or processes change in a real way. Date your revisions.

Chemical inventory list. Current at all times. No retention period is set, but keep prior versions at least three years so you can show what was on site during a given period if an injury surfaces later.

SDS documents. OSHA requires SDS to be kept for the duration of employment plus 30 years for any substance employees may have been exposed to, under 29 CFR 1910.1020, the access to medical records standard ^[10]. In practice, keep SDS documents for discontinued products too, or at least a record of their identity and hazards.

Training records. The HazCom standard sets no minimum retention period, but three years is defensible. Keep the date, the chemicals covered, the trainer's name, and each employee's acknowledgment.

PPE hazard assessment. Keep the written certification indefinitely, or at least as long as the assessed tasks exist.

Injury and illness records. OSHA 300 log requirements apply to breweries with 10 or more employees. Chemical exposure injuries go on the log. Keep them five years ^[7]. File an incident report for any recordable incident.

In a state-plan state, check whether state rules add anything. California's Cal/OSHA, for one, runs a Hazard Communication standard with some differences in training and documentation.

How do you keep the program current as the brewery grows?

A program written for a three-person nanobrewery won't carry a 15-person production shop. The chemicals may be identical, but the number of workers exposed, the volume handled, and the complexity of the operation all shift the risk.

Build review triggers into the document itself. Review when you add a chemical. Review after a chemical-related near-miss or injury. Review when you add equipment that involves chemical contact. Review once a year no matter what.

Assign ownership. In a small brewery, that's usually the head brewer or the operations manager. One named person keeps the SDS binder current, updates the inventory, schedules training for new hires, and answers questions. If it's everyone's job, it's nobody's job.

Past 10 employees, your recordkeeping load grows. Add ammonia refrigeration at scale, and process safety management rules may apply. If a worker develops an occupational illness tied to chemical exposure, you'll want exposure records that reconstruct what they worked with and when.

Make the program findable. A document buried in a shared drive that only the owner knows about fails an inspection and fails the workers who need it. Post a one-page summary in the production area. Put the SDS binder somewhere obvious. Fold it into new-hire orientation instead of leaving it as an afterthought.

One more SafetyFolio note, and then I'll stop: if you're spending more time maintaining the paperwork than running the brewery, a structured program generator cuts the administrative drag while keeping you in the format OSHA inspectors expect.

What does an OSHA inspection look for in a brewery chemical program?

OSHA compliance officers follow a consistent inspection protocol for HazCom. Knowing what they check is useful less for passing an inspection and more for finding your own real gaps.

Common HazCom inspection items:

1. Can the employer produce a written HazCom program on request? 2. Is there a chemical inventory list, and does it match what's actually on site? 3. Is there an SDS for every chemical on the inventory? 4. Can workers reach SDS documents without management stepping in? 5. Are all containers labeled, including secondary containers? 6. Can workers describe the hazards they work with, the protective measures, and how to find an SDS? (Inspectors ask workers directly.) 7. Are training records available, showing who was trained, on what, and when? 8. Are PPE selections backed by a written hazard assessment?

For breweries, inspectors who know the industry also look at CO2 monitoring, confined space procedures for fermenters, and whether the emergency eyewash stations referenced in ANSI Z358.1 sit within a 10-second travel distance from where caustic chemicals get handled.

The most common brewery-specific citation besides HazCom itself is a thin or missing confined space program for fermenters and bright tanks. If your written program doesn't touch it, close that gap before any inspection.

OSHA's general guidance on what a complete HazCom program looks like sits on OSHA's website, along with the letters of interpretation the agency has published over the years. Read even one or two of those letters and you'll see how OSHA handles the edge cases.

Frequently asked questions

Is a written chemical handling program legally required for a brewery with only two employees?

Yes. OSHA's Hazard Communication Standard at 29 CFR 1910.1200 applies to any employer in a covered industry whose workers may be exposed to hazardous chemicals, with no minimum employee count. A two-person brewery using caustic cleaners or CO2 must have a written HazCom program, current SDS documents, and documented training.

How often do I need to train employees on chemical safety?

OSHA requires training before a worker is first exposed to a hazardous chemical and whenever a new chemical enters the workplace. There's no mandatory annual retraining interval in the HazCom standard itself, but most compliance attorneys recommend annual refreshers. If an incident happens or a worker clearly doesn't know the hazards, retrain regardless of the schedule.

Can I use digital SDS management instead of a paper binder?

Yes. OSHA allows electronic SDS systems. The requirement is that an SDS must be accessible to employees during their work shift without barriers. A tablet or computer dedicated to SDS access in the production area works. A system behind a manager login or stuck in an office does not. Many small breweries run both: a physical binder for common chemicals and electronic access for the full inventory.

Do I need an SDS for CO2 in my brewery?

Yes. CO2 is classified as a hazardous chemical under GHS because it is an asphyxiant. It belongs on your chemical inventory and has an SDS. Gas suppliers must provide SDS documents for CO2. Workers in areas where CO2 is stored or accumulates must be trained on its hazards, including the asphyxiation risk and emergency response.

What is the OSHA fine for not having a hazard communication program?

Under 2024 OSHA penalty levels, a serious violation runs up to $16,131 per violation. A willful or repeated violation runs up to $161,323 per violation. HazCom citations often come in multiples: one for no written program, one for missing SDS, one for unlabeled containers, one for inadequate training. The total adds up fast for a small operation.

Do I need a separate confined space program for my fermenters?

Almost certainly yes. Fermenters that workers could enter, and that can hold CO2, meet OSHA's definition of a permit-required confined space under 29 CFR 1910.146. A compliant program needs a written permit system, atmospheric testing before entry, attendants, rescue procedures, and trained workers. It's separate from your HazCom program and one of the most commonly cited gaps in small brewery safety.

What happens if a contractor comes in to service my glycol chiller and encounters my chemicals?

You must inform contractors about the hazardous chemicals they may be exposed to in your facility and the protective measures you have in place. The written HazCom program must address contractor communication. In practice, that means a pre-work briefing and giving contractors access to the relevant SDS documents before they start.

Does peracetic acid require a respirator in a brewery setting?

It depends on concentration and ventilation. OSHA's PEL for peracetic acid is 0.4 ppm as a ceiling limit. If ventilation is adequate and workers aren't generating mist or aerosol, chemical splash goggles and gloves may be enough. If workers spray PAA in enclosed spaces or at high concentrations, air monitoring or a conservatively selected respirator may be required. Check Section 8 of the SDS for your specific product.

How do I handle a chemical that arrives without an SDS?

Request the SDS from the manufacturer or importer before letting workers use the product. Under 29 CFR 1910.1200, chemical manufacturers and distributors must provide an SDS with the first shipment of a hazardous chemical. If a supplier can't or won't produce one, that's a red flag about the supplier. Don't use the chemical until you have the SDS and can train workers on its hazards.

Should my brewery have an eyewash station, and where does it need to be?

OSHA references ANSI Z358.1 for emergency eyewash and shower equipment. Plumbed eyewash stations must sit within 10 seconds of travel (roughly 55 feet) from any area where caustic or acid could splash workers. If your CIP station or mixing area is farther than that from a plumbed eyewash, you need either a closer station or a self-contained unit in that area. Gravity-fed portable units get flushed weekly and maintained per the manufacturer's instructions.

Does my brewery need a Tier II chemical inventory report filed with the state?

Possibly. Under EPCRA Section 312, facilities storing certain hazardous chemicals above threshold planning quantities must file annual Tier II reports with state and local emergency planning agencies. Anhydrous ammonia, for example, carries a 500-pound reporting threshold. Most small brewery cleaning chemicals have much higher thresholds, but if you store large quantities of anything on the EPCRA Extremely Hazardous Substances list, check with your State Emergency Response Commission.

How do I document the PPE hazard assessment OSHA requires?

OSHA requires a written certification under 29 CFR 1910.132(d)(2) naming the workplace evaluated, the person who did the assessment, and the date. In practice, a one-page form listing each task, the chemical hazards present, and the PPE selected satisfies it. Sign and date it. Review it when chemicals or tasks change. It doesn't need to be elaborate. It needs to exist.

What's the difference between a safety data sheet and the old material safety data sheet?

The SDS replaced the MSDS when OSHA updated the Hazard Communication Standard in 2012 to match the Globally Harmonized System (GHS). The SDS uses a standardized 16-section format consistent across all manufacturers, so finding specific information like exposure limits (Section 8) or spill response (Section 6) is faster. Older MSDS documents don't follow this format and should be replaced with current GHS-format SDS documents.

Can the brewery owner write the chemical handling program themselves, or do they need a consultant?

You can write it yourself. OSHA doesn't require a certified professional to author a HazCom program. What matters is that the program covers every required element: written document, chemical inventory, SDS management, labeling procedures, and training. Many small brewery owners write solid programs using OSHA's free small business guides, their suppliers' SDS documents, and a template as a starting structure.

Sources

1. OSHA, Hazard Communication Standard 29 CFR 1910.1200: HazCom requires a written program, SDS for every hazardous chemical, container labels, and employee training before exposure; SDS must be accessible to employees during their work shift.
2. Bureau of Labor Statistics, Occupational Injuries and Illnesses in Food and Beverage Manufacturing: Chemical exposures account for a meaningful share of nonfatal occupational injuries in food and beverage manufacturing.
3. OSHA, Penalties: Under 2024 OSHA penalty levels, a serious violation is up to $16,131 per violation; a willful or repeated violation is up to $161,323 per violation.
4. CDC/NIOSH, Carbon Dioxide in Craft Brewing Hazard Alert: CO2 asphyxiation has caused multiple brewery worker deaths; CO2 is colorless, odorless, and accumulates in low areas without warning.
5. OSHA, Personal Protective Equipment Standards 29 CFR 1910.132-138: OSHA requires a written PPE hazard assessment certified in writing, with the date and assessor's name; employers must train workers on when and how to use PPE.
6. OSHA, State Plans: About 25 states and territories operate OSHA-approved state plans; state plans must be at least as effective as the federal standard and may be stricter.
7. OSHA, Recordkeeping Rule 29 CFR 1904: OSHA 300 log requirements apply to employers with 10 or more employees; injury and illness records must be retained for five years.
8. OSHA, Permit-Required Confined Spaces 29 CFR 1910.146: Fermenters that workers may enter and that can contain CO2 qualify as permit-required confined spaces under OSHA's definition, requiring written permits, atmospheric testing, attendants, and rescue procedures.
9. OSHA, Process Safety Management 29 CFR 1910.119: Facilities with 10,000 pounds or more of anhydrous ammonia trigger OSHA's Process Safety Management standard.
10. OSHA, Access to Medical and Exposure Records 29 CFR 1910.1020: SDS documents must be retained for the duration of employment plus 30 years for substances to which employees may have been exposed.
11. NIOSH, IDLH Documentation for Carbon Dioxide: NIOSH sets the immediately dangerous to life or health (IDLH) value for CO2 at 40,000 ppm (4%); OSHA's PEL for CO2 is 5,000 ppm as a time-weighted average.
12. EPA, Emergency Planning and Community Right-to-Know Act (EPCRA) Section 312 Tier II Reporting: Facilities storing hazardous chemicals above threshold planning quantities must file annual Tier II reports; anhydrous ammonia has a 500-pound reporting threshold under EPCRA Section 312.