Compliance Tier II Reports Due March 1 2018

January 26, 2018

Reminder Compliance Tier II Reports Due March 1

It’s that time of the year to start reviewing your chemical inventory storage for calendar year 2017. March 1st comes quickly, and it takes time to collect, review, and organize the inventory data to complete accurate and timely Tier II submissions. This reporting season has a new requirement of reporting the Occupational Safety and Health Administration (OSHA) Hazard Communication Standard (29 CFR 1910.1200) data that will replace the existing hazard reporting information.

A major change for facilities reporting in 2018 is the change in the rule, effective January 1, 2018.  The United States Environmental Protection Agency (USEPA) will replace the five existing hazard categories under the reporting rule with the hazard categories found within the revised OSHA Hazard Communication Standard (29 CFR 1910.1200) for Tier II reportable substances.  Reporting in 2018 will require facilities to review their Safety Data Sheets for each reportable substance to identify the Hazard Communication Standard hazards for their Tier II report. For more information on this change, you can read about Hazard Communication Standard (29 CFR 1910.1200) here.

Tier II reports, or Emergency and Hazardous Chemical Inventory Forms, are required by the USEPA under the Emergency Planning and Community Right-to-Know-Act (EPCRA) to inform local officials about chemicals used at facilities in their jurisdiction. These Tier II reports outline the types of safety risks the various chemicals pose, and explain the potential hazards to the community should an accident or release occur. The reports are filed annually with local officials (i.e., local fire departments and Local Emergency Planning Committees [LEPC]) and State Emergency Response Commissions (SERCs) to help agencies and communities plan for and respond to chemical emergencies.

Reporting Thresholds

The reporting threshold is dependent on the storage quantities of substances based on the USEPA established Threshold Planning Quantity (TPQ), typically they are:

  • 10,000 pounds of a material stored on-site that has a Safety Data Sheet; or

  • 500 pounds of an extremely hazardous substance or less if the TPQ is lower.

The Hazardous Substance Threshold Planning Quantities for common chemicals stored at facilities include ( for details on TPQ check out the USEPA website):

  • 10,000 pounds of ice melt;

  • approximately 1,560 gallons of fuel oil;

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

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

  • approximately 45 gallons of sulfuric acid or 2,500 pounds of lead-acid batteries (including those found in forklifts, emergency engines, and computer uninterrupted power systems [UPS]).

 


Deadline:

All Tier II Reports are Due March 1, 2018 and typically require you to file using the USEPA Tier2 Submit software.   Some States have developed their own reporting tools in lieu of the USEPA software.  You can find details to the state reporting requirements on the USEPA’s website here. Below are links for additional details regarding New England state filing requirements:

New England Tier II Reporting requirements:

 

Connecticut Tier II Reporting Requirements:


   

Maine Tier II Reporting Requirements:

   

Massachusetts Tier II Reporting Requirements:

   

New Hampshire Tier II Reporting Requirements:


 

Rhode Island Tier II Reporting Requirements:

   

Vermont Tier II Reporting Requirements:


 

Additional Compliance Reporting Reminder

Also, Biennial Hazardous Waste Reporting pursuant of 40 CFR 262.41 is due on March 1, 2018 for Facilities that were a Large Quantity Generator (LQG) in calendar year 2017 – you can read more about Biennial reporting here.

Need help?

If you have questions about preparing for or submitting a Tier II report or Biennial Hazardous Waste report, please call or e-mail our team:

Suzanne Pisano, Director of Compliance
(978) 679-1600
slpisano@geoinc.com

Jeni Pisani, Compliance Project Manager
(207) 606-1043
japisani@geoinc.com

Tim Kipp, Senior Associate
(860) 894-1022
twkipp@geoinc.com

 

Visit the USEPA's Tier II page to learn more.