Tier II Hazardous Chemical Inventory Reports Due in Houston, Dallas, Austin, San Antonio, all of Texas and nationwide.
March 1st is the due date for all manufacturing and non-manufacturing facilities with one or more covered hazardous chemicals to fill out Tier II forms to report chemical inventory data to their local fire departments, local emergency planning committees, and state emergency response commissions.
Why a Tier II Hazardous Chemical Inventory Report is Needed?
The first thing to remember is the Tier II report is about more than just environmental management — it is also an important part of your corporate social responsibility (CSR).
The purpose of this form is to provide state and local officials and the public with information on the general hazard types, storage volumes, and locations of hazardous chemicals present at your facility.
The data collected is used by emergency responders to develop risk assessments. It’s also used during emergency situations, like fires.
The Tier II report helps firefighters and hazmat technicians respond to your facility with the correct protective gear and spill response equipment.
Who Needs to do a Tier II Hazardous Chemical Inventory Report?
Not every facility with hazardous chemicals must submit the Tier II report. Only companies storing hazardous chemicals above minimum thresholds as set by the EPA are required to fill out and submit a TIER II report.
A “hazardous chemical” is any chemical you are required to have on a safety data sheet (SDS) under OSHA’s standard.
The Minimum Tier II reporting thresholds have been established under SARA Title III, Section 312. These thresholds are as follows:
- Extremely Hazardous Substances, the reporting threshold is 500 pounds or the threshold planning quantity (TPQ), whichever is lower. Some reporting thresholds are as low as 10 pounds.
- All Other Hazardous Chemicals for which facilities are required to have or prepare an SDS, the minimum reporting threshold is 10,000 pounds.
TIER II Reporting Season is Closing Quickly!!
Tier II Reports are due by March 1 to the State Emergency Response Commission, Local Emergency Planning Committee, and local fire department in most states. Tier II Reports detail all chemical material stored on-site over the minimum threshold as set by the EPA.
What Needs to be Reported in a Tier II Report?
You need to report all hazardous chemicals that were present at your facility at any time during the previous calendar year at levels that equal or exceed reporting thresholds.
What are Required Tier II Reporting Elements?
- Facility information
- Chemical description of materials used at the facility
- Individual chemical constituents
- Physical and health hazards
- Maximum and average daily amounts
- Storage types, conditions, and locations
- Additional information verifying reporting status
What are Examples of Reporting Chemicals, Items, Substances, Products and Mixtures?
Acids/Caustics, Ammonia (gas & solutions), Antifreeze, Asphalt, Batteries (forklifts, generators), Cement/Sand, Chlorine/Hypochlorite, Cleaners/Degreasers/Solvents, Compressed Gases (O2; H2; CO2; N2), Fertilizers, Gasoline/Diesel Fuels, Heating Oil, Liquefied Natural Gas (LNG), Metals/Alloys, Paints, Pesticides, Propane, Refrigerants (ammonia; R22;R56), Hydraulic fluid, Lubricants
What are Typical Industry and Business Sectors that Might Meet EPCRA Reporting Requirements?
Auto Body, Bioengineering, Bus Companies, Chemical Formulators, Cold Storage/Ice Manufacturing, Colleges/Universities, Concrete (ready-mix), Electronics, Golf Courses, Chemical Distribution, Manufacturers, Metal Fabrication, Metal Plating, Oil/Gas/Propane, POTWs/Water Treatment Plants, Pharmaceuticals, Plastic Manufacturers & Processors, Recyclers, Scrap Yards, Waste/Disposal/Storage, Warehouses/Distributors
Are You Preparing Your Tier II Reporting Due on March 1st?
Remember, Tier II Report, must be submitted by March 1st each year, to your State Emergency Response Commission, Local Emergency Planning Committee and local fire department. Failure to comply with Tier II reporting requirements can cost your organization.
It is important to take the time to carefully review your facility to determine the number of chemicals stored onsite and understand if these quantities require reporting.
What are a Few Helpful Tips for Completing your Tier II Report this Year?
- Get a jump start on reporting – don’t wait until the last week of February to start.
- Review your state’s reporting requirements to determine if anything has changed.
- Determine which chemicals will need to be reported, then review those specific SDS’s to determine the hazards.
- Remember to include your lead-acid batteries from fork trucks and UPS Systems in your evaluation (sulfuric acid is considered an Extremely Hazardous Substance).
- Maintain a copy of the report and paid invoice (if applicable) as proof of your submission.
What are Common Tier II Reporting Mistakes?
Determining what chemicals, you need to report isn’t always easy.
Do you have electric forklifts on-site? Batteries in electric forklifts contain sulfuric acid, an EHS. And if you have over 500 pounds of sulfuric acid on-site, you need to account for that in your Tier II report. One electric forklift battery can weigh up to 3,000 pounds, with 330 pounds of that being sulfuric acid. So, if you have two electric forklifts and batteries on-site, you need to complete a Tier II report.
Take a proactive approach to environmental compliance. Call RSB today for a no-obligation talk about your TIER II reporting.
Contact RSB Environmental for all of your environmental needs.
RSB Environmental 1-833-910-2535 or email at info@rsbenv.com
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