Is the Tier II Report Giving You Headaches?
Tier II reports for 2019 were due earlier this week and this year was no different from past years- the volume of support requests spiked in the weeks leading up to the March 1st filing deadline. Why the increase in support requests? We tend to see the same set of issues from multiple customers that are scrambling to prepare their reports by fixing underlying problems with their inventory. Many of these issues are preventable and what follows is a practical guide to avoiding some of the common issues associated with preparing and filing the Tier II report.
What is the Tier II Report and Who Needs to File It?
The Tier II report is required under Section 312 of the Emergency Planning and Community Right-to-Know Act of 1986, also known as EPCRA. The report is designed to provide state and local officials, as well as the general public, with information about the locations and amounts of hazardous materials within a facility.
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.
Preparing Your Inventory for the Tier II Report
Keeping an accurate inventory of chemicals is a key prerequisite to preparing the Tier II report properly. Surprisingly, many organizations struggle with maintaining their inventory so they scramble to do an inventory audit in the weeks leading up to the March 1st filing deadline. Organizations that do take the time to keep track of their inventory throughout the year have less to fix when the report is due.
If the Tier II report called for submitting your entire inventory, it would be easier to prepare. The problem is that they don’t want everything, e.g., they don’t want you to include non-hazardous products like distilled water in the report. Additionally, since the thresholds vary from chemical to chemical, not only do you need to figure out if it’s reportable, but you also need to know how much of it you have and cross-reference with the threshold amount for that specific chemical.
All of this sounds easy enough right? Well, it probably is if you have a relatively small inventory of a few hundred chemical containers. But what if you have a larger inventory with thousands of different chemical containers? Even if you keep track of all of these containers, in Excel for example, you still have to consolidate like chemicals, tally up the quantities, cross-reference with the required threshold, etc. It requires time and effort to get it right, and then you have to do it again next year.
Chemical Inventory Software Makes the Tier II Report 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!