Tier II Triggers

White Paper: Common Triggers and Thresholds for Tier II Reporting for Warehouses

Introduction

Under the Emergency Planning and Community Right-to-Know Act (EPCRA), Tier II reporting is a critical part of ensuring that emergency responders, state and local authorities, and the public are informed about the types and amounts of hazardous chemicals stored at various facilities. Warehousing operations, particularly those classified under NAICS 4931 (Warehousing and Storage), are often subject to these reporting requirements due to the nature of materials stored and used on-site. This white paper outlines the common triggers and chemical thresholds that require warehousing facilities to file Tier II reports.

What is Tier II Reporting?

Tier II reporting is a requirement under EPCRA Section 312, which mandates that facilities storing or using hazardous chemicals above specific thresholds must submit an annual inventory of these chemicals to local authorities. The primary goal is to ensure that emergency responders and local officials have knowledge of potentially dangerous chemicals in the event of a chemical-related emergency.

Common Tier II Reporting Triggers for Warehouses

Warehouses, due to the variety of goods and materials they handle, frequently exceed Tier II reporting thresholds. The following are the most common triggers that warehouse operators should be aware of.

1. Hazardous Chemical Storage

The most common trigger for Tier II reporting is the storage of hazardous chemicals above the following thresholds:

• 10,000 pounds for hazardous chemicals not classified as Extremely Hazardous Substances (EHS).

These chemicals can include:

• Solvents (e.g., acetone, toluene)

• Cleaning agents (e.g., ammonia-based products, chlorine bleach)

• Lubricants and oils

• Fuel storage (e.g., gasoline, diesel, propane)

Even routine-use chemicals, such as those used for maintenance or sanitation, can trigger reporting if stored in significant quantities.

2. Extremely Hazardous Substances (EHS)

Facilities storing or using Extremely Hazardous Substances (EHS) in amounts above the Threshold Planning Quantity (TPQ) or 500 pounds, whichever is lower, must file a Tier II report. Common EHS chemicals include:

• Sulfuric Acid: Found in lead-acid batteries used in electric forklifts.

• Anhydrous Ammonia: Used in refrigeration systems in refrigerated warehouses.

• Chlorine: Used in water treatment systems.

For example, a warehouse storing more than 500 pounds of sulfuric acid (typically found in lead-acid batteries) would be required to file a Tier II report.

3. Electric Forklifts

Warehouses commonly use electric forklifts, which may trigger Tier II reporting due to the hazardous materials contained in the batteries. The most common substances in these batteries include:

• Sulfuric Acid: An EHS with a reporting threshold of 500 pounds.

• Lead: A hazardous chemical with a reporting threshold of 10,000 pounds.

For warehouses operating a fleet of electric forklifts, the sulfuric acid or lead content in the batteries may exceed these thresholds, triggering the requirement to file a Tier II report.

4. Compressed Gases and Refrigerants

Many warehouses utilize compressed gases and refrigerants, particularly in cold storage operations. The storage of these chemicals can trigger reporting if the thresholds are exceeded:

• Ammonia: A commonly used refrigerant, which is also an EHS with a threshold of 500 pounds.

• Freon and other refrigerants: Although not classified as EHS, large quantities of these chemicals can easily exceed the 10,000-pound threshold for hazardous chemicals.

5. Fuel Storage for Backup Generators

Many warehouses have backup generators powered by fuels like diesel, natural gas, or propane. The storage of fuel for these generators can trigger reporting if the quantity exceeds 10,000 pounds.

• For example, storing approximately 1,500 gallons of gasoline or 2,380 gallons of propane would exceed the 10,000-pound reporting threshold.

6. Chemical Inventory Changes

If a warehouse facility experiences a significant increase in the amount of hazardous chemicals stored on-site, it may trigger Tier II reporting for the first time. This can occur due to:

• An increase in inventory levels.

• Expansion of operations leading to the storage of additional types or amounts of hazardous chemicals.

7. Mixtures of Chemicals

Mixtures containing hazardous chemicals should also be evaluated. If a mixture contains a hazardous chemical component, and the total amount of that component exceeds the threshold, Tier II reporting may be required. For example:

• A cleaning solvent containing sulfuric acid may trigger a Tier II report if the total amount of sulfuric acid in the mixture exceeds the 500-pound threshold.

8. Flammable and Combustible Materials

Warehouses often store flammable and combustible materials, which, if stored in quantities exceeding the thresholds, require reporting. These can include:

• Paints and solvents.

• Aerosol cans with flammable propellants.

• Fuels used for forklifts or generators.

9. Water Treatment Chemicals

Warehouses that operate water treatment systems (for boilers, cooling systems, or drinking water) may use chemicals that require Tier II reporting. These chemicals can include:

• Chlorine.

• Sodium hydroxide.

• Hydrochloric acid.

If stored in quantities exceeding the thresholds, these chemicals may also require Tier II reporting.

Tier II Thresholds to Watch

It’s important to note the specific thresholds for the hazardous chemicals stored in warehouses:

• 500 pounds for EHS chemicals such as sulfuric acid or ammonia.

• 10,000 pounds for non-EHS hazardous chemicals such as solvents, fuels, and lubricants.

Conclusion

Warehousing operations, particularly those involving the use of electric forklifts, hazardous materials, compressed gases, or large quantities of fuel, are likely to meet the thresholds for Tier II reporting. Regular inventory assessments and chemical tracking are essential for compliance, ensuring that facilities meet their reporting obligations under EPCRA. By understanding the common triggers and thresholds, warehouse managers can ensure that they are prepared to file accurate Tier II reports, helping to protect their employees, emergency responders, and the surrounding community in the event of an emergency.