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Are You Ready for Tier II Inventory Reporting?

The Federal government created programs under the Emergency Planning and Community Right-to-Know Act (EPCRA) that focus on environmental, health, and safety issues related to businesses that use, store, and handle hazardous and toxic chemicals. This regulation was spurred by catastrophic disasters, including the 1984 Bhopal Disaster, which have killed or injured people and severely damaged the environment. One of these programs under EPCRA is known as Tier II Chemical Inventory reporting.  In this program, facilities that store certain hazardous chemicals must make material information available to state and county emergency planning officials, as well as local fire departments.  In essence, these agencies need to know what is in a facility, in the event of an emergency that extends beyond the capabilities of site personnel.

So what has to be reported?

Those facilities that store hazardous chemicals, as that term is defined in 40 Code of Federal Regulations 1910.1200(c), above certain threshold quantities must submit an annual Tier II Inventory Form. In general, the threshold quantity is 10,000 pounds (approximately four 55-gallon drums of most liquids), but there is a lower threshold for some extremely hazardous substances. That appears to include almost everything. Not really. There are exclusions for many substances, one of which includes food, food additives, color additives, drugs, or cosmetics regulated by the Food and Drug Administration.  Many automotive fueling stations are also excluded, as long as storage capacities are below certain volumes and the storage tanks are in compliance with federal regulations. Tier II reporting is not a complicated process, but states have differing submittal requirements (some electronic, some paper) and differing reporting agencies. It is best to know and understand the requirements for your state, as the fines for failure to submit can be staggering. The bottom line on Tier II reporting is that emergency response agencies just want to know and understand how they can best protect the environment, personnel, and nearby human populations in the event of an incident. If you need some assistance determining the reporting requirements for your facility, give AKT Peerless a call and we can help out.

 

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