It’s that time of year again: the March 1 deadline for submitting the Tier I or Tier II Chemical Inventory Report under the Emergency Planning and Community Right-to-Know Act (EPCRA) is fast approaching.
Tier Reporting Requirements
You must comply with these reporting requirements if your facility holds a threshold planning quantity (TPQ) of any hazardous chemical.
Defining a Hazardous Chemical
Hazardous chemical, in this context, “means any hazardous chemical as defined under 29 CFR 1910.1200(c)….” [40 CFR370.66] If the Occupational Safety and Health Administration (OSHA) requires you to have a Safety Data Sheet (SDS) for a substance, it’s a hazardous chemical. The most common chemical hazards are explosives, flammables, poisons, corrosives, reactive/unstable chemicals, and chronic health hazards (cancer-agents, mutagens, etc.).
Threshold Planning Quantities
The default TPQ for most substances is 10,000 lbs. or more at any time during the year. For certain extremely hazardous substances designated at 40 CFR 355, Appendix A, the default TQP is 500 lbs. or less. Higher TPQs apply to fuels stored in underground storage tanks at retail gas stations.
Believe it or not, while the chemical inventory report system is mandated and overseen by the United States Environmental Protection Agency, these reports don’t go directly to the EPA. They go to your State Emergency Response Commission (SERC), your community’s Local Emergency Planning Committee (LEPC), and the local fire department (FD).
Different Types of Tier Reports
Section 311 of EPCRA technically requires facilities to provide a copy of an SDS for each chemical to the authorities, but in most cases, a list of chemicals is acceptable. Per Section 312 of the Act, facilities must also provide detailed information about the type and amount of hazardous chemicals they keep in inventory. The EPA offers two different means to comply with this mandate: the broad Tier I report and the more specific Tier II report. The Agency has left it up to each state to choose which one to require. At this point in time, most State authorities require facilities to report their chemical inventories using the Tier II form, and through electronic rather than paper systems.
For more information from EPA on hazardous chemical inventory reporting, click here.
The full regulations for hazardous chemical inventory reporting are found in 40 CFR 370.
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