EPCRA Chemical Inventory Reporting Due March 1

March 1 is the deadline for facilities that store hazardous chemicals to submit Tier I/II chemical inventory reporting under the Emergency Planning and Community “Right-to-Know” Act (EPCRA).

This information ensures that emergency personnel know what chemicals are present if they come on site during a natural disaster, chemical release, fire, or other emergency at or around the facility.

Cheat Sheet: EPCRA Tier I/II Reporting

Who Submits Tier II Reporting?

EPCRA requires facilities that store hazardous chemicals in certain quantities to share information with Local Emergency Planning Committees (LEPCs), State Emergency Response Commissions (SERCs), and fire departments. This information ensures that emergency personnel know what chemicals are present if they come on site during a natural disaster, chemical release, fire, or other emergency at or around the facility.

EPCRA Tier I/II reporting requirements also differ by state. Examples include states listing a wider range of reportable substances, imposing lower reporting thresholds, or assessing a filing fee. There are two forms, a Tier I Form and a Tier II Form. Generally, local emergency responders and State regulations dictate which form(s) facilities must submit. Most facilities submit the Tier II.

A facility must also respond with a Safety Data Sheet (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.

EPCRA Reporting: Finding Your SERC, LEPC, or Fire Department

What Chemicals Are Covered?

If your facility is required by OSHA’s Hazard Communication Standard (HCS) to maintain an SDS 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.

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)]

For most reportable chemicals, the reporting threshold is 10,000 pounds or more. For extremely hazardous substances (EHS) listed in 40 CFR 355, Appendix A, the reporting threshold is either the Threshold Planning Quantity (TPQ) or 500 pounds, whichever is lower.

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

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.

Tags: EPA, EPCRA, Tier II reporting