The Emergency Planning and Community Right-to-Know Act (EPCRA) Tier II reporting program collects information on hazardous chemicals stored at facilities. Facilities must keep Safety Data Sheets (SDSs) for these chemicals and submit either the SDSs or a list of hazardous chemicals to the State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC), and local fire department by March 1st of each year. This information helps emergency responders and supports community emergency planning. Facilities should gather the following data to determine reporting applicability and thresholds.
Chemical Information
- Hazardous chemicals: Any chemical for which the facility must maintain a Safety Data Sheet (SDS) under OSHA regulations.
- Extremely Hazardous Substances (EHS): If the facility stores EHS chemicals above 500 pounds or the Threshold Planning Quantity (TPQ), whichever is lower.
- Thresholds for hazardous chemicals: Facilities must report if they store 10,000 pounds or more of any hazardous chemical. *
- Special thresholds for certain facilities: For example, retail fuel stations have higher thresholds for gasoline (75,000 gallons) and diesel (100,000 gallons), provided tanks are underground and compliant with federal regulations.
Facility Information
- Facility name and complete address: Including coordinates to accurately identify the location.
- North American Industry Classification System (NAICS) code: To classify the type of business or industry.
- Maximum number of occupants: This helps assess potential risks in emergencies.
- Risk Management Program (RMP) ID number: If applicable, especially for facilities subject to EPA’s RMP requirements.
Contact Information
- Owner or operator contact details: Name, phone number, and email address of the person responsible for the facility.
- Emergency coordinator contact details: The individual responsible for emergency response coordination at the facility.
- Person responsible for filing the Tier II report: Contact information for the person handling the submission.
- Billing Contact: Contact information for the person handling invoices for Tier II fee payments.
Chemical Inventory Information
- Chemical name or common name: As listed on the SDS.
- Maximum amount of each chemical present during the previous year: An estimate of the highest quantity stored at any point during the year.
- Average daily amount of each chemical: To provide a clearer picture of regular storage levels.
- Storage method and location: A brief description of how and where chemicals are stored within the facility. Reporters must include a site plan showing storage locations, emergency exits, and fire extinguishers.
State and Local
- If requested by local authorities such as the State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC), or local fire department, a facility may need to submit a Tier II report regardless of the chemical quantities stored.
- Some states are more stringent and require a Tier II report to be submitted for facilities storing hazardous substances of 100 pounds or 500 pounds.
VIEW STATE THRESHOLD DIFFERENCES
Exemptions
Some chemicals and situations are exempt from reporting:
- Chemicals used in routine agricultural operations or household products intended for general public use.
- FDA-regulated substances like food additives, drugs, and cosmetics are also exempt from Tier II reporting.
This data helps determine whether a facility meets reporting thresholds and ensures compliance with federal and state-specific Tier II reporting requirements.
Contact Lara McAlister for #furtherinsight.