By Rachel Powell
Tier II Emergency and Hazardous Chemical Inventory Reports, commonly referred to as “Tier II”, is due annually on March 1
st. The following is a quick overview of reporting requirements.
What is EPCRA?
The Emergency Planning and Community Right-to-Know Act of 1986 was created to help communities plan for chemical emergencies. It also requires industry to report on the storage, use and releases of hazardous substances to federal, state and local governments. EPCRA has four major provisions and serves as the governing body for Tier II reporting.
What makes a chemical reportable under Tier II?
Any OSHA-hazardous chemical stored over the federal threshold quantity of 10,000 pounds or more and any extremely hazardous substance (EHS) stored in quantities of 500 pounds or its threshold planning quantity (TPQ), whichever is less. Individual states may have more stringent reporting requirements. Exceeding the threshold at any time during the reporting year triggers the reporting requirement.
What are EHS chemicals?
EPA has designated EHS chemicals as those which could cause serious irreversible health effects from accidental releases. 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 a section that lists specific location(s) within a facility where reportable chemicals are stored. In addition, the type of container being utilized and exact maximum amount (usually measured in pounds) of hazardous chemicals present at a 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 can vary, Tier II reports must be filed annually with the State, County (LEPC) and local Fire Department. Additional information regarding filing criteria by state, including what fees are associated, can be found at
https://www.epa.gov/epcra/state-tier-ii-reporting-requirements-and-procedures.
How can I prepare for this next year?
Don’t let the March 1 annual Tier II reporting deadline sneak up. Since the spring deadline covers materials for the previous calendar year, it’s important to track all chemicals/products that enter and leave your facility on an ongoing basis. Maintaining on-site inventory throughout the year will allow for a smooth Tier II reporting season.
For the past seven years Rachel Powell has served as a Chemical Data Management Specialist at Cornerstone. She assists clients in setting up and maintaining their Safety Data Sheet Foundation System. On a monthly basis she serves as a facilitator who trains new users. She serves as a Tier II Emergency and Chemical Report filer for our clients on an annual basis.