Are You Prepared for the March 1 Tier II Reporting Deadline?
As you start to prepare for the new year, make sure you don’t forget about your regulatory requirements! The beginning of the year means it’s time to file many regulatory reports, including your Tier II report. The annual Tier II filing deadline – March 1 – will be here before you know it, so it’s a good time to start planning for it now.
Hazardous Chemical Storage Reporting
Section 312 of the Emergency Planning Community Right-to-Know Act (EPCRA) of 1986 requires facilities to submit Emergency and Hazardous Chemical Inventory Reports – also known as Tier II reports – by March 1 each year to their State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC), and local fire department(s). Failure to comply with Tier II reporting requirements can be costly: Each violation of EPCRA Section 312 may result in civil penalties of up to $54,789 per day.
Do Your Chemicals Meet the Reporting Thresholds?
Each year you need to carefully review your facility to determine the quantity of chemicals stored onsite and understand if these quantities require reporting via the annual Tier II report. Tier II reporting thresholds include:
- Extremely hazardous substances (EHSs):500 pounds (227 kg) or the threshold planning quantity (TPQ), whichever is less. A list of EHSs can be found here.
- All other hazardous substances:10,000 pounds (4,540 kg) for any material that has a Safety Data Sheet (SDS).
The Tier II report due on March 1, 2020 must include information on all hazardous chemicals present at your facility during 2019 in amounts that meet or exceed the thresholds mentioned above. Reporting details include the CAS number; a brief description of how and where the chemicals are stored; and estimates of the average daily and maximum yearly amounts of the chemicals present onsite.
In addition to ensuring you’re complying with the EPA’s regulations, accurately preparing and submitting your Tier II report is important for emergency preparedness. Correctly reporting chemicals, their quantities, locations, and hazards to your SERC, LEPC, and local fire department alerts these agencies to chemical hazards at your facility should an emergency occur. These agencies can also properly plan and prepare for such emergencies. Having properly informed emergency responders allows for a more effective and well-organized response and can potentially limit liability and injuries during a response effort.