For facilities storing hazardous chemicals, the deadline for Tier II inventory reporting is quickly approaching.
Governed by the Emergency Planning and Community Right-to-Know Act, known as EPCRA, Tier II Chemical Inventory reports are due March 1 for the previous reporting year. This is a fixed deadline, and extensions are not granted. Delayed reports are issued significant fines.
This federal mandate is designed to protect humans and the environment, requiring municipal and industrial facilities to report hazardous or toxic substances housed there during the previous year.
That doesn't mean every business with a bottle of Clorox on the shelf is held to that standard. Tier II reports must be reported by businesses that:
- Have 10,000 pounds or more of any hazardous chemical.
- Stored materials on the Environmental Protection Agency's (EPA) Extremely Hazardous Substance list at its Threshold Planning Quantity.
- Stored 75,000 gallons of gasoline or 100,000 gallons of diesel fuel.
- Have been asked to do so by their local fire department or emergency planning committee.
Facilities required to comply will need to document the types, quantities and locations of on-site hazardous chemicals. They do that so first responders, emergency planners and the public have access to that vital information during a chemical incident or emergency.
It is easiest to compile this information if you make it routine to record all chemicals entering your facility. One simple way to do that is by using monthly purchasing records. This allows you to start with a full inventory list and cross-check the required materials for Tier II reporting.
Using that smaller list, you'll need to report the physical and health hazards of each chemical, the maximum amount on-site, the average amount on site each day, the number of days it was on-site and how it was stored. Be sure to include details such as conditions and locations for chemical storage.
It helps if you also include a site map for the chemicals, so that emergency responders can access it quickly. Confidential location information on your Tier II report is an option, however.
Compiling the report involves maintaining detailed inventories, safety data sheets and emergency contact details. Accuracy is key, so be sure that all information is double-checked.
Staying up to date with accurate reporting is key to helping emergency responders plan – and act – in a crisis. It also reassures the public that this facility is transparent about its operations. Tier II chemical inventory reporting represents a proactive commitment to public safety, environmental responsibility and community awareness. By meeting these reporting obligations, these facilities reinforce their role as responsible stewards of safety and environmental concerns.
If you are unsure of your obligations under this regulation, contact us contact us or call 920.453.0700. Our experts can help with Tier II chemical inventory reporting. Fehr Graham will help ensure proper handling of your Tier II chemical inventory report.
Elisabeth Stier is an Environmental Health and Safety Scientist who designs and organizes information for environmental programs, conducts environmental trainings, audits, Industrial Hygiene sampling and completes regulatory compliance reports and workplace safety audits. Reach her at This email address is being protected from spambots. You need JavaScript enabled to view it.. |