By March 1, certain facilities will be required to submit hazardous chemical inventory reports, commonly referred to as Tier II reports. In a recent webinar, Tier II Reporting, Strategies for Meeting Compliance Obligations Ahead of the March 1, 2016, Reporting Deadline, speaker Lori Siegelman, CIH, CSP, CHMM, of W&M Environmental Group, LLC, discussed who is impacted and what they must do to comply with Tier II reporting requirements under the Emergency Planning and Community Right-To-Know Act (EPCRA). If you missed it, this webinar will be presented live, again, on February 18 (register now).
Tier II reports must be submitted annually by facilities that have any extremely hazardous substance (EHS) or other hazardous chemical on-site in quantities above established thresholds at any time during the reporting year. The reporting thresholds for EHSs are 500 pounds (lbs) or the threshold planning quantity, whichever is less. The threshold for all other hazardous chemicals is 10,000 lbs. Siegelman detailed these reporting thresholds, paying specific attention to what is considered a “hazardous chemical.” She explained that a hazardous chemical is defined by the Occupational Safety and Health Administration (OSHA), and that typically, if OSHA requires a safety data sheet (SDS) for the chemical, it must be included on the Tier II report unless the SDS specifically states “no hazard,” “Tier II reporting not required,” or something to that effect.
Siegelman went on to discuss various exemptions from Tier II reporting, noting that hazardous waste is exempt, but the inclusion or exclusion of other waste products is somewhat of a “gray area.” She recommended contacting the appropriate regulatory agency to get its interpretation as to whether to include certain waste products.
The webinar went on to cover the methods of reporting, and Siegelman discussed various electronic reporting options and summarized some of the state differences in reporting methods and thresholds. As part of the reporting, facilities are required to provide North American Industry Classification codes, and Siegelman noted that the structure of these codes has changed and facilities that are updating a previous year’s report will need to verify that the correct codes are being used.
The webinar concluded by covering a few of the trickier issues associated with Tier II reporting, such as reporting mixtures and lead acid batteries as well as providing some simple compliance tips. Siegelman reminded reporters to pay attention to ancillary activities, such as refrigeration systems, forklifts, etc., and to start preparing reports early to avoid the paperwork crunch as the deadline approaches.
Tier II reports are due March 1, but it is not too early to start gathering your data. So, get started!