Tier II Hazardous Material Reporting in Wisconsin | When Are Tier 2 Reports Due?

EPCRA 302/311/312 reports (“Tier II Reports”) are due on an annual basis to the State and Local Emergency Planning Committee and local emergency response agencies, such as the fire department. The information provided is used in the evident of an emergency, such as a fire, to evaluate potential chemical and other hazards at the property, and to select appropriate protection equipment and fire fighting techniques. EPCRA reporting facilities disclose the types, quantities and locations of hazardous materials. Facilities also provide with Safety Data Sheets for each material.

There are separate reporting requirement for hazardous materials (any material that requires a Safety Data Sheet under OSHA rules) and Extremely Hazardous Substances (EHS) which are a specific chemicals listed by US EPA. A very common example of one such EHS is sulfuric acid.

When are Tier II reports due in Wisconsin?

The Tier 2 report is due March 1 of each year and is based on chemicals stored at your site during the previous calendar year. Reporting can be completed by using the Wisconsin Hazmat Online Planning and Reporting System.

Caltha LLP provides technical support to facilities in Wisconsin that submit reports under EPCRA 311 and EPCRA 312.

Click here for a summary of some recent changes to EPCRA Tier II reporting requirements

For more information or to request a quote go to:
Caltha LLP EH&S Compliance Support Services

Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

Environmental Compliance Training, Waste Management Training, SPCC Training

Caltha LLP provides a wide range of training programs to industrial and government sector clients to meet the requirements of State and EPA rules, permits and related spill and emergency preparedness rules. Training can be provided to large or small groups and is provided either in person at your location, or through a live webinar format. For further information and to request a quote, go to Employer's Environmental Health and Safety Training Center.


The training sessions commonly requested include:

• Hazardous waste management training
• SPCC annual training
• Spill response training
• DOT hazardous material (HazMat) triennial recertification and initial training
• Facility compliance training overview (covering a wide range of typical facility environmental compliance topics)
• Internal compliance auditor training
• Industrial and construction site stormwater discharge permit training
• Stormwater monitoring training
• Training for site inspections

Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

MPCA Delays Enforcement Action On Handling of Hazardous Aerosols & Cylinders

The Minnesota Pollution Control Agency has extended its compliance deadline for one important change to its policies regarding management of spent aerosol cans and gas cylinders that contain hazardous chemicals. Historically, the MPCA had elected not to take enforcement action against hazardous waste generators who empty aerosol cans and cylinders by releasing pressure into the atmosphere, including those who puncture cans with equipment fitted with carbon or other filtration systems to capture vapors. The agency considers this "abandonment" of hazardous waste, which is prohibited.


The MPCA had planned to change its enforcement policy as of January 1, 2017. which would require generators using such equipment to find an alternate means of handling aerosol cans and cylinders. The agency recently announced that it has extended this change to enforcement policy until January 1, 2018, to allow facilities more time to modify their practices, if needed.


Minnesota is one of only a few States that allows aerosol cans and gas cylinders to be handled as though they were universal wastes, although they are technically not regulated as universal wastes under State and Federal rules. MPCA has established some minimum requirements generators must comply with to take advantage of this policy.


Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

When Are The New EPA Hazardous Waste Generator Rules Effective?

The final US EPA Hazardous Waste Generators Improvement Rule was published in the Federal Register on November 28, 2016. The effective date for the rule is May 30, 2017.


Click here to review a summary of key new requirements for very small quantity generators (VSQG), small quantity generators (SQG) and large quantity generators (LQG).


Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

New Rule On Episodic Hazardous Waste Generation For VSQG & SQG Facilities

One of the persistent issues for hazardous waste generators has been when short term spikes in hazardous waste generation elevate facilities to a higher generator class, resulting the requirement to meet additional generator requirements. The Hazardous Waste Generator Improvements Rule addresses this issue by creating another type of waste generation – episodic hazardous waste generation. Because large quantity generators are not limited by monthly generation, this rule only affects VSQG and SQG generators.

Two types of episodic hazardous waste generation are created – planned and unplanned. Planned episodes, as the name suggests, can be planned ahead of time and include activities such has facility cleanups, obsolete inventory disposal, demolition projects, etc. Unplanned episodes include spills, fires, and other emergency incidents. Under the new rule, hazardous waste generated during these events will not count against monthly waste total and will not change generator status, if conditions are met.

Generators taking advantage of this option will be limited to one event per calendar; with opportunity to petition for one additional unplanned event in the same year.

For planned events the generator must:

• notify agency at least 30 days prior,
• identify start/end dates (60 day max),
• have EPA ID #, and
• ship within 60 days using a hazardous waste manifest.

For an unplanned event the generator must notify agency within 72 hr after incident. For either type of episode, the generator must label wastes “Episodic Hazardous Waste” and identify hazard characteristic (example, corrosive, flammable). Episodic waste totals are not added to monthly facility total; separate records must be kept of episodic wastes.


Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website 

EPA Hazardous Waste Generator Improvements Rule - What States Are Affected?

The Hazardous Waste Generator Improvements Rule is now signed and  published in the Federal Register on November 28, 2016. This leaves hazardous waste generators to sort out how this will affect them, and when.


Immediate Affect of the Hazardous Waste Generator Improvements Rule
The Generator Improvements Rule modified the Federal rules under RCRA and therefore has direct affect on hazardous waste generators located in States that have not been delegated RCRA authority (Iowa and Alaska) and some other areas, including Tribal lands. However, many States have incorporated portions of the RCRA rules by reference into their authorized programs – therefore, in these States revisions to Federal RCRA rules can have an immediate affect on State rules. This can significantly increase the population of hazardous waste generators that will be affected by the Hazardous Waste Generator Improvements Rule s ix months after publication in the FR - on May 30, 2017.

For generators located in States that have not incorporated generator requirements by reference, the impact of the rule revision will be uncertain. Rule changes will only become effective when States modify their own hazardous waste generator requires. To add to the uncertainty, States will only be required to modify their rules to incorporate portions of the Hazardous Waste Generator Improvements Rule that are MORE stringent than current rules. Other portions of the new EPA rules that add flexibility, are less stringent, or are incorporate clarifications to the rule would not need to be addressed by States to maintain their authorized programs under RCRA.

Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website 

MPCA Rules On Puncturing and Venting Spent Aerosol Cans Changes January 1, 2017

In Minnesota, generators can puncture waste aerosols or gas cylinders that have been shown to be empty or that have been evaluated as non-hazardous, as long as any unavoidable liquid residuals are collected and properly managed.


However, hazardous waste aerosols and gas cylinders may no longer be punctured or vented in Minnesota after January 1, 2017, unless all hazardous waste propellant gases, product gases, and liquids are captured and properly disposed. MPCA does not allow charcoal and activated carbon filters to be used to capture hazardous waste propellants or gases for disposal.


The deliberate release of hazardous waste propellant or compressed gas to the atmosphere has been prohibited by the Minnesota Hazardous Waste Rules for many years, but MPCA chose not to enforce this prohibition. This allowed generators and collection sites to puncture hazardous waste aerosols and dispose of ignitable hazardous waste to the atmosphere. This practice is not allowed after 1/1/2017.


UPDATE: The deadline for this policy change has been revised.




Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website