Tier II for Warehousing

The Ultimate Tier II Reporting Checklist for Warehouses

Tier II reporting is a critical requirement for facilities that store hazardous chemicals in quantities exceeding specific thresholds. As a warehouse manager, ensuring compliance not only helps you meet regulatory obligations but also protects employees, the community, and the environment. This checklist will guide you through the Tier II reporting process for your warehouse.

1. Determine Reporting Requirements

• Review Reporting Thresholds: Check if the quantities of hazardous chemicals stored in your warehouse exceed the EPA’s reporting thresholds:

  • Extremely Hazardous Substances (EHS): Typically, the threshold is 500 pounds or the Threshold Planning Quantity (TPQ), whichever is lower.

  • Other Hazardous Chemicals: The general threshold is 10,000 pounds for most hazardous chemicals.

• Check State and Local Regulations: Verify if there are additional state or local reporting requirements, as some states may have stricter rules or lower thresholds.

2. Compile Your Chemical Inventory

• Conduct an Inventory Audit: List all chemicals stored on-site, including raw materials, cleaning agents, lubricants, paints, fuels, and any other potentially hazardous substances.

• Verify SDS Information: Gather the Safety Data Sheets (SDS) for each chemical, as they contain vital information needed for reporting, such as chemical names, CAS numbers, hazard categories, and storage details.

• Quantify and Record: Note the maximum amounts of each chemical present at any time during the previous calendar year, as well as the average daily amount and the number of days the chemical was stored.

3. Identify Storage Locations and Conditions

• Map Storage Areas: Identify all storage locations within your warehouse (e.g., racks, containers, tanks). Include outdoor areas, as these also need to be reported.

• Specify Storage Conditions: For each chemical, document the storage method (e.g., containers, tanks), temperature control measures, and any secondary containment systems. This information is crucial for emergency responders.

4. Categorize Chemicals by Hazard Type

• Classify Hazardous Chemicals: Use the information from the SDS to categorize each chemical by hazard type (e.g., flammable, corrosive, toxic). The classification will help determine the appropriate hazard categories for your Tier II report.

• Identify Extremely Hazardous Substances (EHS): Mark chemicals classified as Extremely Hazardous Substances and note their specific Threshold Planning Quantities (TPQs).

5. Complete the Tier II Reporting Form

• Use Tier2 Submit Software: Download the latest version of the EPA’s Tier2 Submit software to complete your Tier II report electronically.

• Include All Required Information: Make sure to provide the following details for each hazardous chemical:

  • Facility information (name, address, emergency contacts).

  • Chemical identity and CAS number.

  • Physical and health hazards (e.g., flammable, reactive, health hazard).

  • Storage amounts (maximum and average daily quantities).

  • Storage conditions (location, temperature controls, containment measures).

  • Emergency contacts for your facility.

• Verify Accuracy: Double-check that all the information in your report is accurate and complete. Errors or omissions can lead to compliance issues or fines.

6. Submit Your Tier II Report

• Submit Electronically: Submit the completed Tier II report using the method required by your state. Most states accept electronic submissions through the Tier2 Submit software or an online system.

• Send to Appropriate Agencies: Send copies of your report to the required agencies, which typically include:

  • The State Emergency Response Commission (SERC).

  • The Local Emergency Planning Committee (LEPC).

  • Your local fire department.

7. Maintain Records and Documentation

• Keep Copies of the Report: Retain copies of your submitted Tier II report and all supporting documentation (e.g., chemical inventory, SDS) for at least 5 years, as required by the EPA.

• Document Reporting Dates: Record the dates of submission and confirmations received from agencies. This documentation serves as proof of compliance.

8. Prepare for Inspections

• Train Staff: Ensure that warehouse staff and emergency contacts are familiar with the information in the Tier II report and understand emergency procedures.

• Update Your Report: Keep your Tier II report updated with any changes in chemical inventory or storage conditions. Report any significant changes to the SERC, LEPC, and fire department as required.

9. Plan for Annual Reporting

• Set Reminders: Tier II reports are due annually by March 1st for the previous calendar year. Set reminders well in advance to review and update your chemical inventory, gather data, and complete the report.

• Review Changes in Regulations: Check for any changes in federal, state, or local regulations that might affect your reporting requirements for the new year.

Additional Tip:

• Stay Informed: Subscribe to industry updates and regulatory news to stay current on changes in Tier II reporting requirements and best practices.

By following this checklist, warehouse managers can efficiently navigate the Tier II reporting process, ensuring compliance with federal, state, and local regulations.