TIER II COMPLIANCE REPORTING SOFTWARE

Accurate Tier II Compliance Reporting

The Emergency Planning and Community Right-to-Know Act (EPCRA), Section 312(a) requires the owner or operator of facilities subject to 311(e) of EPCRA to submit an emergency and hazardous inventory form March 1^st of each year to the State Emergency Response Commission (SERC), the Local Emergency Planning Committee (LEPC), and the local fire department. Section 312 outlines two “tiers” for reporting information on hazardous chemicals at a facility. Tier I contains general information on hazardous chemicals at a facility, and Tier II contains specific information on hazardous chemicals present at the facility.

The Tier II forms must be submitted annually on March 1^st and sent to:

1. Your State Emergency Response Commission.
2. Your Local Emergency Planning Committee.
3. The fire department with jurisdiction over your facility.

Tier II reports help firefighters and hazmat technicians respond to your facility with the correct personal protective gear and spill response equipment. Tier II data is used in mapping the locations of facilities storing hazardous materials and their distance to sensitive populations (schools, nursing homes, etc.). Data can also be used to protect the environment and citizens through spill prevention, mitigation, and response to hazardous materials incidents.

Tier II Compliance

Facilities that are required to maintain SDSs under Occupational Safety and Health Administration (OSHA) regulations for hazardous chemicals stored or used in the workplace must submit a Tier II report.

Other facilities with chemicals in quantities equal or exceed the following thresholds must report:

• For Extremely Hazardous Substances (EHSs) (40 CFR part 355 Appendix A and B), either 500 pounds or the Threshold Planning Quantity, whichever is lower.
• For gasoline (all grades combined) at a retail gas station, the threshold level is 75,000 gallons (or approximately 283,900 liters), if the tanks(s) was stored entirely underground and was in compliance throughout the preceding calendar year with all applicable Underground Storage Tank (UST) requirements at 40 CFR part 280 or requirements of the State UST program approved by the Agency under 40 CFR part 281.
• For diesel fuel (all grades combined) at a retail gas station, the threshold level is 100,000 gallons (or approximately 378,500 liters), if the tank(s) was stored entirely underground and the tank(s) was in compliance throughout the preceding calendar year with all applicable UST requirements at 50 CFR part 280 or requirements of the State UST program approved by the Agency under 40 CFR part 281.
• For all other hazardous chemicals: 10,000 pounds.

States are given the flexibility to implement hazardous chemical inventory reporting requirements, as appropriate for the needs of their community. This flexibility includes adding more chemicals, setting lower reporting thresholds, and creating a reporting form or format that included information beyond that required by the federal reporting requirements.

 ERA assists facilities with Tier II Reporting by:

• Reviewing SDSs- We verify vendors, products, and processes to on-site for changes to ensure accurate reporting.
• Investigating chemicals that are commonly misreporting such as lead acid batteries in forklifts, large tanks, and large quantities of wood dust. 

ERA has helped file hundreds of Tier II reports, and has even integrated Tier II reporting capability into our Environmental Software. If you have any questions or concerns about your own Tier II reporting requirements, try a free, customized demo to explore ERA’s Environmental Management Software. 

How ERA Improves Tier II Reporting for You

The methodology behind ERA’s software is built on total accuracy and rigorous data-gathering, basing reports on your facility’s measured, actual daily activities. This complete approach excludes the data-gaps present in other software packages. 

• TIER II ERA Processing Options:
  By Chemical-When you process/report by chemical, Tier II Hazard Classifications are automatically pre-selected based on Chemical/CAS and GHS regulatory settings (from the ERA Master Chemical List).
• By Product (Mixtures)-New Tier II Classification Tab at Product Specifications and Product Categories allow you to add classifications for each SDS entered.
• Process Tier II by usage, period, and sources included.
• No-versioning Software. All EPA changes and updates are made at no extra cost, for better reporting.