Make sure you don’t forget your regulatory responsibilities for the upcoming year! Your Tier II report is one of many regulatory reports that must be submitted at the beginning of each year, more specifically, before the submission deadline on March 1st, 2023. It’s time to start organizing right away! We have prepared five steps to help you prepare your Tier II report.
1. Understand the federal reporting regulations for hazardous chemical storage
Section 312 of the Emergency Planning Community Right-to-Know Act (EPCRA) of 1986 mandates that facilities must submit Emergency and Hazardous Chemical Inventory Reports, also known as Tier II reports, by March 1st of each year to their State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC), and local fire department. Non-compliance with Tier II may have severe financial repercussions: Each breach of EPCRA Section 312 is punishable by civil fines of up to $50,000 per day.
2. Which facilities are required to submit?
You must perform a comprehensive assessment of your facility each year to determine how many chemicals are kept there and whether these numbers must be included in the yearly Tier II report. According to Tier II reporting requirements, facilities with chemicals in quantities that equal or exceed the following thresholds must report:
Organizations that store hazardous chemicals that exceed EPA established thresholds are required to submit the report; however, the reporting threshold can vary depending on the chemical. For example, most chemicals have a 10,000-pound threshold, but it’s lower for extremely hazardous substances- either 500 pounds or the Threshold Planning Quantity (whichever is lower). There are also variations that are determined by the facility type. For example, gas stations have a higher 75,000-gallon threshold for gasoline and 100,000 gallons for diesel.
3. What Should Be in Your Tier II Report?
Information on any hazardous substances existing at your site in quantities that meet or exceed the aforementioned standards must be included in the Tier II report, which is due on March 1, 2023. The reporting data should contain the CAS number, a brief description of how and where the hazardous chemicals are stored, and estimates of the average daily and maximum annual quantities of hazardous chemicals present onsite. EPA recently revised the Tier II form to include additional information which are useful to both the planners and responders. Tier II form requires facility and employee contact information for non-emergency and emergency matters, and information about stored chemicals in the facility.
The following is a list of some of the information required on the inventory form:
- The chemical name or the common name as indicated on the SDS (MSDS) sheet
- An estimate of the maximum amount of the chemical present at any time during the preceding calendar year and the average daily amount
- A description of the manner of storage of the chemical
- The location of the chemical at the facility
- An indication of whether the owner of the facility elects to withhold location information from disclosure to the public
4. How do I submit a Tier I or Tier II Inventory Report?
Facilities that meet EPA’s requirements must submit an emergency and hazardous chemical inventory from their SERC or TERC, LEPC or TEPC, and the local fire department annually.
Click on the regulation to see all Tier I and Tier II form instructions published by the EPA.
Chemical Inventory Software Makes the Tier II Reporting Easier
Chemical Safety’s environmental compliance software has the Tier II as well as several other common environmental regulatory reports built-in. The reports are always current and electronic submission options are preconfigured. The Tier II report is also fully integrated with the rest of our environmental health and safety software suite. For example, each inventory container is linked to a manufacturer-specific safety data sheet and its corresponding hazard data, so the software knows what’s reportable and what the thresholds are. The software does all of the heavy lifting for you!
