RCRA Biennial and Tier II Reporting Due March 1

Posted on 2/16/2024 by Nick Waldron

For many facilities, March 1 is the deadline for two environmental reporting submissions—the RCRA hazardous waste Biennial Report and Tier I/II chemical inventory reporting under EPCRA.

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Who Submits the RCRA Biennial Report?

The Federal RCRA program requires Large Quantity Generators (LQGs) of hazardous waste to submit the Biennial Report (Form 8700-13A/B) by March 1 of every even numbered year. The Biennial Report details the types, amounts, and final disposition of hazardous waste generated during the most recent "reporting year"—i.e., the most recent odd-numbered year. 

Cheat Sheet: RCRA Biennial Reporting
Cheat Sheet: What's My RCRA Generator Status?

LQGs must also re-notify EPA of their activities by submitting Form 8700-12 by the same March 1 deadline. Re-notification is required for Small Quantity Generators (SQGs) as well, once every four years. 

Be sure to check your state’s hazardous waste program; the rules may be stricter!

Who Submits Tier II Reporting?

If your facility is required by OSHA’s hazard communication standard (HCS) to maintain a Safety Data Sheet for a “hazardous chemical” and you had more than the threshold quantity on site during the reporting year, you must submit Tier II chemical inventory data by March 1.

Cheat Sheet: EPCRA Tier I/II Reporting 

Reporting must be submitted to state and local emergency responders.

The threshold for most covered chemicals is 10,000 pounds. Extremely Hazardous Substances trigger reporting requirements when the amount on site exceeds 500 pounds or the chemicals’ Threshold Planning Quantity—whichever is lower.

A facility must also respond with a SDS or Tier II information when a local or state emergency planning authority (LEPC, SERC, or fire department) requests information about one or more chemicals at the facility.

OSHA’s definition of a “hazardous chemical”:

“any chemical which is classified as a physical or health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified.”

—OSHA Hazard Communication Standard [29 CFR 1910.1200(c)]

Hazard criteria evolve over time with updates to the HCS. For example, when OSHA incorporates changing global standards from the Globally Harmonized System of Classifying and Labeling Chemicals, or GHS.

Check your state’s Tier II Reporting requirements.

Understand the Rules Affecting Your Site

Professionals who complete this course develop a streamlined approach to manage hazardous waste from cradle-to-grave—and meet recording and recordkeeping requirements.

Those who complete this course can identify the environmental regulations that apply to their facility and locate key requirements to achieve compliance with the Clean Air and Clean Water Acts to EPCRA, TSCA, Superfund, and more.

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