Complete Story
02/15/2017
Tier II Report Deadline is March 1st
Submitted by Gary Jones, Assistant Vice President, EHS Affairs, Printing Industries of America
The deadline to file your Tier II report is March 1, 2017 and, if not filed on time, it could subject you to enforcement actions including significant penalties.
Tier II reports, more officially known as Emergency and Hazardous Chemical Inventory Forms, are required to be submitted annually to local fire departments, Local Emergency Planning Committees (LEPCs) and State Emergency Response Commissions (SERCs) under Section 312 of the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA). The purpose of Tier II reports is to provide these agencies with specific information on hazardous chemicals stored at facilities so that they can prepare for and respond to any chemical emergency that may occur.
Tier II reports are required if a company had stored at any one time during the calendar year 2016 enough of a chemical that would exceed the reporting threshold. There are two reporting thresholds. The first is for Extremely Hazardous Substances (EHSs), which are identified on a specific list. The reporting threshold is 500 pounds (or 227 kg.) or the threshold planning quantity (TPQ), whichever is lower. (EHSs and their TPQs are listed in 40 CFR part 355, Appendix A and B.)
For all other hazardous chemicals for which facilities are required to have or prepare an SDS, the minimum reporting threshold is 10,000 pounds (or 4.540 kg.).
It is also important to understand that some states and counties have much lower reporting thresholds or may have an additional list of chemicals that they want a facility to submit at Tier II report. In addition, even if a reporting threshold is not exceeded, Section 312 of Emergency Planning and Community Right-to-Know Act requires that the owner or operator of a facility submit their Tier II form if so requested by a State emergency response commission, a local emergency planning committee, or local fire department with jurisdiction over the facility.
The most commonly reported chemical for printing operations is sulfuric acid. This is because it is considered an Extremely Hazardous Substance and its reporting threshold is 500 pounds. Any facility that has a couple of battery powered forklift trucks may have to report the sulfuric acid in the batteries. The lead that is in the batteries has a 10,000 pound reporting threshold, which means that depending upon the size and number of batteries, a facility may have to also report due to lead.
Other larger quantities of materials that are inventoried and can trigger reporting include ink, fountain solution, cleaning solutions, propane, and fuel oil. Even though a facility may use more than 10,000 pounds of any of these products, reporting is only triggered if the inventory exceeds the threshold.
If reporting is required, most states now want the information to be reported electronically and not on the paper forms. Some states have their own system while others will accept EPA’s Tier2 Submit files.
If you have any questions or need more information, please contact your BDD.
