Tier II Emergency and Hazardous Chemical Inventory Reports are due annually on March 1. Since these reports cover materials for the entire previous year, it’s important to continually track the chemicals/products entering and leaving your facility. Maintaining on-site inventory throughout the year will allow for a smooth Tier II reporting season. Don’t let the deadline sneak up on you!
The following is a quick overview of the EPCRA regulation and Tier II reporting:
What is EPCRA?
The Emergency Planning and Community Right-to-Know Act of 1986 was created to help communities plan for chemical emergencies. This regulation requires industry to report on the storage, use, and release of hazardous substances to federal, state, and local governments. EPCRA serves as the governing body for Tier II reporting.
What makes a chemical reportable under Tier II?
Reporting is applicable for any OSHA-hazardous chemical stored on site that exceeds the federal threshold quantity of 10,000 pounds, and any EHS stored in excess of 500 pounds or its threshold planning quantity (TPQ), whichever is less. Exceeding the threshold at any time during the reporting year triggers the reporting requirement. It is also important to note that individual states may have more stringent reporting requirements.
What is an EHS?
The Extremely Hazardous Substance (EHS) list identifies chemicals that could cause serious irreversible health effects as a result of a release. A full list of EHS chemicals can be found on epa.gov.
What storage information is needed to file the Tier II?
Reporting requirements include details of specific location(s) within a subject site where reportable chemicals are stored. In addition, the type of container utilized and exact maximum amount (typically measured in pounds) of hazardous chemicals present at the facility at any one time during the previous calendar year must be reported.
How do I know what reporting requirements exist for my state?
Although each state’s reporting system may vary, any subject facility must file a Tier II report annually with the State, County (LEPC), and local Fire Department. Additional information regarding filing criteria by state, along with associated fees, can be found at https://www.epa.gov/epcra/state-tier-ii-reporting-requirements-and-procedures.
Further Information
With a well-organized system in place, compliance with the Tier II reporting requirements is much easier to achieve. Cornerstone is an industry leader in chemical inventory management, electronic SDS imaging, and software management systems. Our proprietary software (FOUNDATION) combines both EPA and OSHA chemical tracking and reporting functions and provides a foundation for all compliance recordkeeping and reporting. Additionally, we have a team of experts who can assist with Tier II reporting and help keep your hazardous chemical data up to date throughout the year, so you will always be ready for the March 1 deadline. To learn more about Cornerstone’s chemical management services, visit our website.
For over seven years, Rachel Powell has worked as a Chemical Data Management Specialist at Cornerstone. She assists clients in setting up and maintaining their Safety Data Sheet FOUNDATION System and facilitates new user training monthly. Additionally, each year, she files Tier II Emergency and Chemical Reports on behalf of our clients.