Are you Ready for the 2021 Tier II Reporting Deadline on March 1st?
Some of the guidance in this post may be out of date. Please review updated information for the March 1, 2023 deadline in the newest blog on Tier II.
The new year has begun, make sure to include meeting your regulatory requirements in your plans! It's time to document numerous regulatory reports from the previous year, including your annual Tier II report. March 1st is the annual Tier II reporting deadline, so make sure to plan ahead!
Why are Tier II Reports Required?
The Emergency Planning Community Right-to-Know Act (EPCRA) of 1986 was created to help communities plan for chemical emergencies. Section 312 states that facilities are required to submit Emergency and Hazardous Chemical Inventory Reports, or 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 result in penalties of up to $59,017.00 per day for every violation.
Do Your Chemicals Meet the Reporting Thresholds?
You should review your facility annually to determine the amount of chemicals stored onsite and to be able to discern whether these chemical 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, 2021 must include details on all hazardous chemicals present at your facility in 2020 in amounts that are equal to or over 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, accurate preparation and submission of 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 notifies them of chemical hazards at your facility should an emergency occur. These agencies appropriately design and plan for such crises. Having well-informed emergency responders allows for a more efficient and organized response and can potentially limit liability and injuries during a response effort.
Let Us Help You Prepare
Our Triumvirate consultants can help you complete and submit your Tier II report by the March 1 deadline. Contact us to ensure you meet your reporting requirements on time!