Tier II Reporting is a vital component of the Emergency Planning and Community Right-to-Know Act (EPCRA). It requires facilities that store hazardous chemicals above certain thresholds to submit an annual report detailing the types, quantities, and storage locations of these chemicals. This information is crucial for emergency responders and local governments, ensuring that appropriate measures are in place to protect the community in case of an incident.
Common Challenges:
Identifying chemicals that meet reporting thresholds.
Correctly categorizing chemical hazards according to OSHA standards.
Preparing and submitting accurate reports to state and local emergency planning commissions.
How We Can Help:
Our compliance consultants guide you through the Tier II reporting process by:
Conducting a comprehensive assessment of your facility's chemical inventory.
Identifying hazardous substances that require reporting.
Compiling the necessary data, including quantities, locations, and hazard categories.
Preparing and submitting your Tier II report on time to meet federal and state requirements.
Providing guidance on record-keeping practices for future reporting and inspections.
By leveraging our expertise, your facility can stay compliant while reducing administrative burdens and mitigating potential penalties.
Navigating environmental regulations can be complex and time-consuming. At Watkins Group, LLC, we simplify compliance by offering tailored solutions for Tier II reporting, TRI reporting, stormwater permitting, SPCC plan development and more.
Office:
888-582-9292
Email:
support@watkinsgroupllc.com
Industry Credentials:
ISO 14001:2015 Environmental Management System Lead Auditor
CESCO - Certified Environmental and Safety Compliance Officer (NREP)
CSRP - Certified Sustainability and Resilience Professional (NREP)
Hazardous Waste Operations and Emergency Response (HAZWOPER 40) OSHA
Occupational Safety and Health Administration
(OSHA 30 - 1910)
In the United States, Tier 2 reports are part of the Emergency Planning and Community Right-to-Know Act (EPCRA), specifically under Section 312. The following entities are generally required to submit Tier 2 reports:
Who: Any facility that stores or uses hazardous chemicals in quantities that meet or exceed the established threshold levels must file a Tier 2 report.
What Chemicals: Hazardous chemicals are defined by the Occupational Safety and Health Administration (OSHA) under its Hazard Communication Standard (HCS). These include any substances for which a Safety Data Sheet (SDS) is required, such as fuels, solvents, acids, or any other materials that pose physical or health hazards.
Thresholds: The reporting requirements typically apply to facilities that have:
10,000 pounds or more of any hazardous chemical.
500 pounds or the threshold planning quantity (TPQ), whichever is lower, for Extremely Hazardous Substances (EHS), as defined by the EPA.
Manufacturing Plants: Facilities that produce or use large quantities of chemicals.
Warehouses and Storage Facilities: Locations that store hazardous chemicals, even if they are not used in production.
Agricultural Operations: Certain farming operations that store pesticides, fertilizers, and other chemicals in significant quantities.
Utilities and Power Plants: Facilities using chemicals for energy production or maintenance activities.
Automotive and Aviation Industries: Businesses that use or store fuels, lubricants, and other chemicals.
Construction Sites: When they store hazardous chemicals exceeding the reporting threshold.
Some federal, state, and local government facilities are also required to report if they handle chemicals above the threshold quantities.
Certain facilities and chemicals may be exempt from Tier 2 reporting, including:
Household Products: When used in the same manner and frequency as a consumer would use them.
Food, Drugs, and Cosmetics: Regulated by the Food and Drug Administration (FDA).
Solids in Manufactured Items: Not intended to be released or pose a health risk during normal use.
Substances Used in Research Labs or Hospitals: Under specific controlled conditions.
Deadline: Facilities must submit Tier 2 reports annually by March 1st for the previous calendar year.
Where to Report: Reports are submitted to the State Emergency Response Commission (SERC), the Local Emergency Planning Committee (LEPC), and the local fire department.
The requirements can vary slightly by state, as some states have additional regulations or lower thresholds for certain chemicals. It's essential for facilities to check both federal and state regulations to ensure compliance.