Environmental Compliance - News

Tier II Reporting due March 1


There are many regulations of which companies must adhere, especially when they work with harmful chemicals or substances. Tier II Reporting, or Emergency and Hazardous Chemical Inventory, is required of certain companies or facilities by the U.S. Environmental Protection Agency.

The requirement is based on the presence of chemicals on a facility’s site. The agency started this system after the 1984 Union Carbide Disaster in Bhopal, India, which was one of the worst industrial accidents in which methyl isocyanide was released and caused 3,800 deaths and injured many. The reports, which are due every March 1, provide information on the average and maximum amounts of hazardous chemicals on site. Companies must list an emergency contact to ensure that a representative can be reached in emergencies. Tier II reports are required under the Community Right to Know Act, and copies must be sent to local fire departments, and state and local Emergency Planning Committees. Emergency responders keep a record of this information so they can respond appropriately when they are called to the site. 

Tier II reports have varying threshold levels for reporting. Sulfuric acid, for example, has a low threshold because of its toxicity and corrosive nature. Having two to three electric forklift batteries can mean that a company needs to file Tier II reports. Companies must file reports if they have any of the following substances:

  • 500 pounds of Extremely Hazardous Substances or more than the threshold planning quantity.
  • 10,000 pounds of all hazardous materials the Safety Data Sheets identify as health hazards.
  • 75,000 pounds of combined gasoline or 100,000 pounds of diesel fuel for retail reporting.

Facilities regularly must report materials with physical hazards like liquid nitrogen or combustible dust. While these reports are due on March 1 each year, should a company add a chemical at any time, it must be reported within 60 days.

The team at Fehr Graham helps many businesses and municipalities with Tier II reporting. We will look at your chemical inventory and decipher what must be reported. 

Contact us today.


Illinois
Amy Trimble
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815.235.7643

Wisconsin
Matt Schroeder
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920.453.0700

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