With the Tier II hazardous chemical inventory reporting deadline on March 1, you’ll need to be fast!
• Have a hazardous chemical,
• In a quantity that equals or exceeds an established threshold,
• Present at your facility at any one time during the year
…then you’ll need to submit a report for that chemical.
To work out which chemicals are hazardous and fit the above criteria, you’ll need to closely examine your substances – check the SDS to see if it may pose a physical or health hazard, for example being an asphyxiant or combustible dust.
There is also a list of Extremely Hazardous Substances you can take a look at in Appendices A & B of 40 CFR 355. This also includes further information about the applicable threshold quantities for reporting.
You’ll need to provide your reports to the State Emergency Response Commission (SERC), your closest Emergency Planning Committee (LEPC), and your local fire department(s) which have jurisdiction over the facility. In many cases, the state’s emergency management department or the state’s environmental protection agency will accept Tier II reports on behalf of SERC. It also pays to take note of how your Tier II report needs to be submitted and whether fees must be paid at the time of submission, as this may differ by locality – for example, some have specialised online software for reporting, or may accept reports on CD or via email.
So don’t delay, as you may risk being one of the organisations facing fines – EPA assessed close to $250,000 in fines for Tier II-related EPCRA violations last year.