With March 1 right around the corner, it’s time to make sure your organization is prepared for the SARA Tier II reporting of hazardous chemicals. These Environmental Protection Agency (EPA) submittals are required annually to make sure emergency responders have the information needed to respond safely to an incident. Known as SARA Tier II reports, they report information on hazardous chemicals at your facility in the prior year. Although reporting methods may vary by state, the March 1 deadline is consistent for all.
According to the EPA, hazardous chemicals are defined as “any element, compound, or mixture of elements that is a physical hazard or a health hazard.” With any hazardous chemical that is used above certain thresholds – 10,000 pounds for most chemicals and 500 pounds for Extremely Hazardous Substances (EHS) – there must also be a Safety Data Sheet (SDS) on site under the Occupational Health and Safety Administration (OSHA) regulations. SDS and Tier II reports are reported online and then separately sent to your local agency, i.e., State or Tribal Emergency Response Commission (SERC or TERC), Local or Tribal Emergency Planning Committee (LEPC or TEPC), or local Fire Department.
It is also important to note the difference between the reporting for Hazardous Chemicals vs. Extremely Hazardous Substances (EHS). While both need to be reported, there are differences based on the type of chemical/substance and what the reporting thresholds are. EHS are defined as “a substance that could cause serious irreversible health effects from accidental releases.” These substances must be reported if the threshold is at 500 pounds or based on the Threshold Planning Quantity (TPQ), whichever value is lower. There are also powered industrial equipment, such as forklifts and generators, which may use lead-acid batteries. If the total amount of sulfuric acid exceeds 500 lbs, it must be reported as an EHS. A list of what is considered to be an EHS can be found at 40 CFR Part 355.
When considering whether your organization reports at or above the threshold outlined, there are guidelines for different media. For example, the reporting threshold for gasoline is 75,000 gallons if the tank was stored underground and fits all other storage and compliance requirements. For diesel fuel, the reporting threshold is 100,000 gallons under the same conditions. All other hazardous chemicals have a reporting threshold of 10,000 pounds although some states, such as California and Louisiana, have lower thresholds. Therefore, it is imperative that you check your state and local regulations and reporting guidelines.
Chemical Safety Software’s cloud-based environmental compliance software includes a library of regulatory reports, as well as the ability to create custom reports. Preconfigured regulatory reports include Federal Tier II, as well as state-specific Hazardous Materials Business Plans (HMBP). The EMS EH&S software suite also includes our California CERS reporting software which features electronic submission.
Most importantly, EMS’ environmental compliance software is regularly updated to stay current with the latest federal, state, and local environmental reporting specifications. Fully integrated with our chemical inventory tracking software and our SDS database, real-time data is pulled directly from the software.
Stay tuned for next month’s article on EPA’s Toxic Release Inventory (TRI) reporting requirement.
