Search

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.

Jump to:

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.

Find a Post

Compliance Archives

Lion - Quotes

Lion's online training is more comprehensive, has better slides, and is a superior training experience than what I would get from other trainers.

Robert Brenner

District Environmental Manager

I will never go anywhere, but to Lion Technology.

Dawn Swofford

EHS Technician

I was able to present my scenario to the instructor and worked thru the regulations together. In the past, I attended another training firm's classes. Now, I have no intention of leaving Lion!

Diana Joyner

Senior Environmental Engineer

Lion was very responsive to my initial questions and the website was user friendly.

Michael Britt

Supply Chain Director

No comparison. Lion has the best RCRA training ever!!

Matt Sabine

Environmental Specialist

Energetic/enthusiastic! Made training enjoyable, understandable and fun!

Amanda Walsh

Hazardous Waste Professional

Best instructor ever! I was going to take my DOT training w/a different provider, but based on this presentation, I will also be doing my DOT training w/Lion!

Donna Moot

Hazardous Waste Professional

The instructor was very engaging and helped less experienced people understand the concepts.

Steve Gall

Safety Leader

The instructor made the class very enjoyable and catered to the needs of our group.

Sarah Baker

Planner

I have over 26 years of environmental compliance experience, and it has been some time since I have attended an environmental regulations workshop. I attended this course as preparation for EHS Audits for my six plants, and it was exactly what I was looking for.

Frank Sizemore

Director of Regulatory Affairs

Download Our Latest Whitepaper

A guide to developing standard operating procedures, or SOPs, that help you select, manage, and audit your hazmat agents and contractors.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.