2019 Compliance Tier II Reports Due March 1st

February 4, 2019

Compliance Tier II Reports Due March 1 2019

2019 is already into its full swing, and it’s that time of year where facility must review its chemical inventory storage for the 2018 calendar year. Like years past, Tier II reports are due to the Environmental Protection Agency (EPA) by March 1st. If you already haven’t started collecting, reviewing and organizing your facility’s chemical inventory data, you’ll want to start as soon as possible, as March 1st isn’t that far away.


Tier II Reports and Who Receives Them


Tier II reports—Emergency and Hazardous Chemical Inventory Forms—are required by the EPA under Section 312 under the Emergency Planning and Community Right-to-Know-Act (EPCRA). The EPCRA requires these reports so local officials have direct knowledge regarding the chemicals that are both used and stored at facilities within their region. These reports are submitted, and outlined, so local agencies understand the safety risks that the chemicals stored might pose, as well as the hazards they might impose upon the community in the event of an accident or chemical release. These annual inventory reports are filed to their State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC) and local fire department to allow for these organizations to prepare themselves if an accident or release occurs, ensuring they have a response plan in place for such chemical agencies.  


What Facilities Are Covered?


Any facilities that store hazardous materials, who are thus required to maintain a material safety data sheet (MSDS), sometimes referred to just as a Safety Data Sheet (SDS), under Occupational Safety and Health Administration (OSHA) regulations, might be eligible to submit a Tier II report. In particular, the reporting threshold that requires a facility to submit a Tier II report depends upon the Threshold Planning Quantity (TPQ) as established by the EPA.


The reporting thresholds designated by the TPQ typically include:

  • 500 lbs. of Extremely Hazardous Substances (EHSs) or the TPQ (Appendix A and Appendix B), whichever is lower; or

  • 10,000 lbs. of a material stored on-site that has a SDS.

More specific thresholds, as determined by the TPQ, for facilities holding hazardous chemicals include:

  • 10,000 pounds of ice melt;

  • 500 pounds of anhydrous ammonia – such as in refrigeration or cooling systems;

  • 10,000 pounds (or 2,500 gallons) of propane; 

  • 100 pounds of anhydrous hydrogen fluoride;

  • 1,000 pounds of sulfuric acid — as used for sulfate salts, synthetic detergents and hydrochloric acid; and

  • 100 pounds of chlorine.  


Deadline and Where to Report


All Tier II reports must be submitted to the EPA and filed with your state agencies and organizations by March 1, 2019. The EPA requires you to submit your Tier II reports through their Tier2 Submitting Software, which has been updated for Reporting Year 2018. Your state agencies might have tools of their own for which you must file your reports through. Information regarding your state’s preferences can be found through the EPA’s Tier II State Requirements webpage.


New England Tier II Reporting Requirements:








New Hampshire:


Rhode Island:




Additional information regarding Tier II reports can be found through the EPA’s website. If you have any questions regarding your facility, whether or not you meet the TPQ thresholds or how to submit your Tier II reports, please call or email our team.

Suzanne Pisano, Compliance Director

slpisano@geoinc.com | 978.679.1600

Contact Suzanne Pisano

John Hinckley, Associate/Air Compliance Specialist

jahinckley@geoinc.com | 603.314.0820

Contact John Hinckley

Tim Kipp, Senior Associate/Compliance Project Manager

twkipp@geoinc.com | 860.894.1002  

Contact Tim Kipp