In the realm of environmental compliance, Tier II reporting plays a critical role in helping emergency responders, regulatory agencies, and local communities understand the types and quantities of hazardous chemicals stored at various facilities. A key component of Tier 2 reporting is identifying whether your facility surpasses the Tier II thresholds, which dictate when and how you need to report your chemical inventory. Failure to comply with these thresholds can lead to significant penalties and safety risks. In this guide, Watkins Group, LLC breaks down everything you need to know about Tier II thresholds to ensure your business remains compliant.
Tier II thresholds refer to the specific quantities of hazardous chemicals stored at a facility that trigger the requirement to submit a Tier II report. These thresholds are determined by the Emergency Planning and Community Right-to-Know Act (EPCRA) and vary depending on the type of chemical, its hazards, and its regulatory classification.
The two primary types of chemicals subject to Tier II reporting are hazardous chemicals and extremely hazardous substances (EHS). These substances are defined based on their potential risks to human health and the environment. Click here for information on Tier II Exemptions.
For most hazardous chemicals, the threshold that requires reporting is straightforward. Any facility that stores or handles 10,000 pounds or more of a hazardous chemical at any time during the year must submit a Tier II report. These hazardous chemicals can include substances such as flammable liquids, toxic chemicals, and corrosive materials.
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)
Examples of Hazardous Chemicals:
Petroleum products like diesel or gasoline
Industrial cleaning chemicals
Solvents and adhesives
Forklift Batteries (more on reporting for batteries here)
Watkins Group, LLC helps facilities identify which of their chemicals meet these thresholds and ensures that all required substances are reported in compliance with Tier II regulations. Whether you handle industrial solvents or petroleum-based products, our team can guide you through the reporting process.
The reporting thresholds for Extremely Hazardous Substances (EHS) are much lower than those for general hazardous chemicals due to their increased risk to public safety. The threshold for reporting an EHS is typically 500 pounds or the Threshold Planning Quantity (TPQ)—whichever is lower.
The TPQ is a set quantity of an EHS that, when exceeded, requires a facility to submit a Tier II report. These substances pose greater risks in the event of an accidental release and include chemicals like chlorine, anhydrous ammonia, and hydrogen fluoride.
Chlorine (TPQ: 100 pounds)
Anhydrous Ammonia (TPQ: 500 pounds)
Hydrogen Fluoride (TPQ: 100 pounds)
Given the lower thresholds, facilities storing EHS substances are much more likely to be required to file Tier II reports. At Watkins Group, LLC, we specialize in helping businesses navigate the complexity of EHS regulations, ensuring that all chemicals meeting these lower thresholds are properly reported.
Meeting or exceeding Tier II thresholds means your facility must file a report to the relevant local and state agencies. These reports provide vital information to emergency responders and local planners who need to be aware of chemical hazards in the event of an emergency.
Failing to comply with these reporting requirements can result in significant financial penalties, operational disruptions, and reputational damage. Under EPCRA, penalties for non-compliance with Tier II reporting can reach $57,317 per day per violation. The consequences for failing to report an EHS or hazardous chemical above the threshold can be especially severe, making it critical to stay ahead of these requirements.
At Watkins Group, LLC, we provide expert guidance on how to identify the chemicals that meet or exceed the Tier II thresholds. Here’s how we approach this process:
Inventory Review: We perform a detailed review of your facility’s chemical inventory to determine which substances fall under Tier II reporting requirements.
Threshold Analysis: Using federal and state guidelines, we calculate the quantities of each chemical to ensure you are aware of any chemicals that exceed the 10,000-pound hazardous chemical threshold or the 500-pound EHS threshold.
Threshold Planning Quantities (TPQ): For chemicals classified as EHS, we review the specific TPQ for each substance and help you understand your reporting obligations.
Compliance Action Plan: We create a tailored action plan for your business to ensure that all chemicals exceeding these thresholds are reported in compliance with Tier II regulations.
While federal guidelines dictate the basic Tier II thresholds, it’s important to note that some states may impose stricter reporting requirements. Certain states require lower thresholds or additional chemicals to be reported. Failing to comply with state-specific thresholds can result in additional penalties and enforcement actions.
At Watkins Group, LLC, we stay up to date on both federal and state-specific reporting regulations, ensuring that your business complies with all relevant laws, no matter where you operate. Whether you’re in California, Texas, or any other state, our team is equipped to help you navigate local reporting rules.
The risks of non-compliance with Tier II thresholds are significant, and the penalties can be crippling. However, by partnering with Watkins Group, LLC, your business can avoid these risks entirely. Here’s how we add value:
Expertise: Our team has years of experience in Tier II reporting and understands the nuances of EPCRA compliance.
Customized Solutions: We offer tailored compliance solutions based on your facility's specific chemical inventory and operations.
Ongoing Support: We provide continuous monitoring to ensure that any changes in your chemical storage are immediately reflected in your reporting obligations, ensuring year-round compliance.
Cost Savings: By avoiding hefty penalties, operational disruptions, and legal fees associated with non-compliance, partnering with Watkins Group, LLC saves you money in the long run.
Understanding Tier II thresholds is essential for any business handling hazardous or extremely hazardous substances. By meeting or exceeding these thresholds, your facility is required to file Tier II reports to ensure the safety of your employees, emergency responders, and the local community. With Watkins Group, LLC, you’ll have a trusted partner that ensures your business remains compliant with both federal and state regulations.
Ready to Get Started?
Contact Watkins Group, LLC today to schedule a consultation and find out how we can assist with all your Tier II reporting needs. Let us help you stay compliant, avoid penalties, and focus on what you do best—running your business.