August 8th of last year, the U.S. EPA proposed several revisions to the Tier I and Tier II report forms to make reporting easier for facilities to complete and to make them more useful for state, local, and tribal agencies. These changes include modifications to existing parts of the forms and add a few new elements as well.
The EPA stresses that the new changes impose the minimal reporting burden possible, since all the information required to complete the new Tier I and Tier II report forms are readily available to any facility. In addition, the changes made to existing elements have made the forms more user-friendly and quicker to complete.
Here's a brief summary of the new information being gathered by the EPA’s proposed changes to the Tier II forms:
- TRI facility ID
- RMP (Risk Management Program) Facility ID
- Facility latitude and longitude
- Number of full time employees, or the total number of people that could occupy the facility (for hotels, universities, etc.)
- Basic contact information, including parent company name, D&B number, address, etc.
- Facility’s Emergency Coordinator contact info
- Tier II information contact info (this refers to the person responsible for preparing the Tier II form)
- Whether the facility is subject to Emergency Planning and/or Chemical Accident Prevention (RMP)
The EPA is also proposing a modification to the range codes for reporting, with narrower ranges, and has suggested that chemicals and mixtures be reported separately.
It’s easy to see from this list that the EPA’s proposed changes haven’t added a significant reporting burden. In fact, some of these changes will require as little effort as checking the appropriate checkbox. It seems that the majority of changes being proposed for the Tier II report forms modify the format of the form itself, rather than create drastic changes in your reporting responsibilities.
Following standard procedure, the EPA is seeking public commentary on the proposed Tier II changes. You have the opportunity to provide comments until October 7, 2011. You can submit your feedback and view the entire document published in the Federal Register using this link: http://www.regulations.gov.
It is important to make your opinion about these proposed changes known. As we have seen in the past, the EPA pays a lot of attention to the public’s commentary and has even taken dramatic actions in order to respond to public opinion.
ERA has helped file hundreds of Tier II reports, and has even integrated Tier II reporting capability into our Environmental Software. So if you have any questions or concerns about your own Tier II reporting requirements, contact us or request a free online demo. We would be happy to help in any way we can!
September 22, 2011