EPA Proposes Revisions to Tier II Reports
For the first time in over 20 years, the U.S. Environmental Protection Agency (EPA) is proposing changes to the Tier I and Tier II chemical inventory reporting forms.
Under the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA), the U.S. Environmental Protection Agency (EPA) requires all facilities with an inventory of hazardous chemicals to file a Tier I or Tier II report each year with State and local emergency response planners.
Over the years, emergency response planners and other stakeholders have identified deficiencies in the existing reporting forms and have asked the EPA to make revisions in order for the Tier II reports to be “…more useful for State and local agencies and to better inform the public on chemical hazards in their communities.”
What New Elements Is the EPA Proposing?
Facility Emergency Coordinator
Regulated facilities are already supposed to designate a facility representative who will participate in the emergency response planning process with State and local authorities. The EPA is proposing that the identity of the emergency coordinator be included on the Tier II form.
Tier I and II Information Contacts
As it stands now, the Tier II report does not include a designated point of contact, which means that State and local emergency response planners have difficulty getting in touch with the person who prepared the Tier II report. If the intent of the Tier II reporting system is to force chemical storage facilities and emergency response planners to coordinate, the lack of a designated point of contact is a problem. Therefore, the EPA is proposing that each Tier II report include the name, title, and contact information of the person knowledgeable of or responsible for completing the Tier II report.
Emergency Planning
The Agency also intends for the new Tier II report to include data on whether the facility is subject to Emergency Planning requirements under Section 302 of EPCRA, or the Chemical Accident Risk Prevention or Risk Management Programs under the Clean Air Act.
What Data Elements Is the EPA Proposing Changes To?
Facility Identification
The EPA is proposing two additional data elements for identifying the owner/operator of a regulated facility. Firstly, in addition to the contact information for the facility proper, the EPA is now requesting the name, address, phone number, and Dun & Bradstreet of the facility’s parent company. Secondly, the EPA is adding a line for the reporting facility’s e-mail address.
New Range Codes for Inventories
The EPCRA statute requires that facilities give an estimate in ranges for the maximum and average amount of hazardous chemicals at a facility. As emergency responders consider the existing ranges too broad, the EPA is proposing a new set of ranges to provide more granularity.
Chemical Information for Mixtures
Because mixtures of hazardous chemicals can be reported as either the amount of mixture or the amount of hazardous chemical in the mixture, the EPA proposes to create separate entries in the Tier II report for mixtures and pure chemicals.
Storage Type/Condition
The Tier II form currently requires facilities to use code numbers to report how chemicals are stored (underground tank, drum, etc.) and under what conditions (temperature, pressure, etc.). The EPA proposes to eliminate the codes and have facilities simply report storage conditions descriptively.
Tags: EPA, EPCRA, new rules, reporting and recordkeeping
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