EPCRA 312 Tier II Reports Due March 1, 2012

EPCRA Tier II Hazardous Chemical Storage Reports are due March 1 for sites subject to hazardous chemical reporting. Under the Federal Emergency Planning and Community Right-to-Know Act (EPCRA), any facility that stores hazardous chemicals can have both one-time and annual reporting, specified in Section 311 and 312 of EPCRA. Under EPCRA, hazardous chemicals are any substances for which a facility must maintain a Material Safety Data Sheet (MSDS) under the OSHA Hazard Communication Standard – if a material has an MSDS, it is considered to be a hazardous chemical under EPCRA. This can include materials which might not immediately be considered “chemicals”, such as batteries, fuels, metals, etc.

EPCRA rules apply to all types of sites, and are not limited to a particular industrial sector – reporting sites can be commercial, institutional, warehousing, retail or any other type of site which could store or use chemicals. Facilities with chemicals in quantities that equal or exceed the thresholds must report. The thresholds can be specific to different types of chemicals and can be as low as 500 pounds for some materials, and as high as 10,000 pounds.

As an overview, to comply with EPCRA hazardous chemical storage reporting requirements, for any hazardous chemical used or stored on-site above threshold amounts, facilities must maintain a MSDS, and submit the MSDSs to their State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC) and local fire department. Over time, if the site recieves revised MSDS, most current MSDS must also be submitted. Facilities must also report an annual inventory of these chemicals by March 1 of each year to their SERC, LEPC and local fire department. Under the Federal rule, facilities could provide a report using either a Tier I or Tier II form. However, in practice most States require the Tier II form be used.

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FAQ: How are Tier I and Tier II reports different?

Caltha LLP provides specialized expertise to clients nationwide in the preparation and submittal of chemical storage reports, preparation of Toxic Release Inventory (TRI) reports, and preparing cost-effective EH&S management programs.


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