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5 Tips for More Effective Tier II Reporting

drawingThe March 1st deadline for Tier II reporting is fast approaching. This means environmental managers across the U.S. are working to collect all of the relevant chemical inventory data needed. If you haven't already started preparing your reports, you should. We've prepared 5 insider tips that will ensure you're doing the right thing...

The first thing to remember is the Tier II report is about more than just environmental management -- it is also an important part of your corporate social responsibility (CSR).

The data collected is used by emergency responders to develop risk assessments. It's also used during emergency situations, like fires.

For your Tier II report, it’s not about how fast you can get it done, it is more important to do the job right.

Follow these 5 Tier II reporting tips to help you do just that: no shortcuts - just honest and complete reporting - kind of like how a hero would do it.

Tier II - By Chemical or by Product?

You have the option of reporting either by chemicals or by products. For example, if you have at least 10,000 pounds of a reportable chemical contained in your inventory of topcoat, you can either report it as the chemical or as the topcoat.

The best way to report is to report it as the topcoat.

Why? Because this is the format most useful to first responders.

During an emergency, firefighters won’t necessarily have time to check the MSDSs of your products to see if they’re hazardous or flammable.

But if they know ahead of time that all the drums of topcoat kept in storage present a danger to them, they can respond accordingly.

Tier II Chemicals - To Group or Not to Group?

You can report certain materials and products as a group if they are similar in composition.

If you have several different products that are all alike (for example, an inventory full of paints that only differ because of color additives) and contain the same reportable Tier II chemical, then you should report them as a group.

Although every individual product might not contain the 10,000 pound reporting threshold, if they are grouped together they might exceed 10,000 pounds.

This sort of consideration can make or break it for emergency services.

Technically, you aren’t required to report the products that don’t exceed the 10,000 pound threshold, but it doesn’t exactly give emergency responders an accurate picture of your facility.

In the end, to a firefighter, two nearly identical products with 5,000 pounds of tier II chemical is the same as one larger, 10,000 pound tank. They both present the same risk.  

When taking this approach, there is one important thing to remember about grouping:

If a single product exceeds the Tier II chemical reporting threshold, you must report it separately instead of grouping it with similar products.

Download the EPCRA Essentials Course  Comprehensive seminar from a former EPA TRI Coordinator - TRI, SARA, Form R

Dealing with Extremely Hazardous Substances (EHS)

If a product contains even just one Extremely Hazardous Substances (EHS) in it, you will need to obey a much lower threshold.

For example, even just one pound of Acrolein is considered reportable, while the threshold is 5,000 pounds for Benzal Chloride.

Pay close attention to your Extremely Hazardous Substances.

It is easy to make a mistake when reporting them if you aren’t fully aware of their unique reporting thresholds. The consequences for risk planning are even greater than most chemicals.

State-Specific Regulations Matter

Always double check your state’s rules about Tier II reporting.

Although the EPA already has guidelines in place, many states have their own regulations about Tier II. These state-specific rules supersede the EPA regulations, meaning that you may have to report, even if the EPA doesn’t require it.

The EPA maintains a list of the state-specific regulations on their website, here.  

Some states have started to make using E-Plan software for your Tier II reporting mandatory. This is a special web application used by emergency responders that ties into the Tier II reports. If your state requires you to use the E-Plan software, you can find it here.

Don’t Make These Common Mistakes

There are three items that tend to be forgotten during Tier II reporting. If you have any of the following on site, make sure you report them (if you exceed the related thresholds).

Lead Acid Batteries

These batteries aren’t typically used during manufacturing, and so often get forgotten. Most of the time, lead acid batteries are found in forklifts and only come into use during site maintenance. Unfortunately, they still pose a significant risk to emergency responders during an emergency. Since they are kept on site and have a SDS, they are still considered a reportable Tier II chemical.

Any Large Tanks

Despite their size, large tanks seem to get forgotten during Tier II reporting season.

Wood Dust

Wood dust can be tricky, because your facility likely doesn’t keep a SDS for wood dust, and so it seems like it shouldn’t be reportable. However, wood dust is classified as Particulate Matter (PM) and is therefore a carcinogen, in addition to being flammable. But if your site contains a large silo or bag house full of wood dust, you should report it.

Download the EPCRA Essentials Course  Comprehensive seminar from a former EPA TRI Coordinator - TRI, SARA, Form R