Companies that store or use chemicals are subject to a host of special requirements, ranging from maintenance of safety data sheets to submittal of local fire department reports. Certain facilities, however, must follow an extra step: Environmental Protection Agency (EPA) Tier II reporting.
The multitude of safety compliance regs and reporting forms can easily overwhelm even the most savvy team, says environmental health and safety expert Joe Keenan. Understanding the thresholds for Tier II reporting is not easy, and reporting to the pertinent state agency, local emergency planning committee, and local fire chief takes time. In an AudioSolutionz webinar, “EPA Reporting: Decipher the Complexities of Inventory Tier II Forms,” Keenan walks EH&S professionals, engineers, plant managers, and others through the Tier II reporting process.
Tier I vs. Tier II: Know Where to Draw the Line
Reporting for Tier I facilities is simpler than for Tier 2 operations—though knowing which tier category you fall into will take some legwork. Tier I facility owners can self-certify and have the option to complete a streamlined plan. Reporting thresholds for Tier II are outlined on an EPA website.
In addition to legwork, reporting also requires a fair bit of math, as facility owners need to calculate chemical mixtures to satisfy the EPA reporting rules.
Tier II: Disclose Harmful Chemicals to Local Authorities
Submission of Tier II forms is required under a section of the Emergency Planning and Right-to-Know Act.
“The purpose of this form is to provide state, local officials, and the public with specific information on potential hazards,” notes the EPA. “This includes the locations, as well as the amount, of hazardous chemicals present at your facility during the previous calendar year.”
Though the Tier II form is not long, EPA packs a lot of questions into each page. The first page is a run-down of the facility, its owner, and contact information. The disclosure page asks for the name of the chemical stored on site, its physical and health hazards, and the maximum amount, average daily amount, and number of days on site. EPA also wants you to detail storage conditions (including pressure and temperature) and locations.
Resource: The agency also has a 12-page set of instructions for how to fill the form out.
In addition to the federal requirements, each state has a set of Tier II reporting procedures. Beware that a few states, such as Colorado, Kentucky, and New York, have their own specific form submittal instructions.
Tier II: Calculate Chemical Mixtures
“If a hazardous chemical is part of a mixture, you have the option of reporting the entire mixture or only the portion of the mixture that is a particular hazardous chemical (e.g., If a hazardous solution weighs 100 lbs. but is composed of only 5% of a particular hazardous chemical, you can indicate either 100 lbs. of the mixture or 5 lbs. of the chemical),” notes the EPA Tier II instructions.
“The option used for each mixture at your facility must be consistent with the option used in your Section 311 reporting.”
Understanding the requirements of the different reporting levels is not easy, adds Keenan—and facility owners and managers should not be afraid to ask for help.
