Community Right-to-Know Tier II
Environmental Reporting Deadlines
The regulations surrounding environmental reporting can seem to be confusing and ever changing. As we near the end of another fiscal year, it's smart to review any regulations that will affect compliance reporting in 2020.
Regarding Community Right to Know Tier II Inventory Reports, does your facility fall under the Community Right to Know reporting guidelines? Most facilities, whether they know it or not, keep hundreds of hazardous materials onsite that might require reporting.
Tier II Reporting: What is it?
Sections 311 and 312 of SARA Title III address emergency and hazardous chemical inventory reporting. Submission of the Tier II form is required under Section 312 of the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA).
Tier II reporting includes the locations, as well as the amount, of hazardous chemicals present at a facility during the previous calendar year. The regulations are intended to provide the public, local governments, fire departments and other emergency officials with the information necessary concerning the potential chemical risks in their communities. This is a federal regulation that requires reporting to the state agency, Local Emergency Planning Committees (LEPCs), and the local fire departments.
Who is Required to Report Tier II?
Are your facilities subject to the annual Tier II reporting? Here's how to know.
Facilities with chemicals in quantities that equal or exceed the following thresholds must report:
- For extremely hazardous substances (40 CFR part 335 Appendix A & B), either 500 pounds or the Threshold Planning Quantity, whichever is lower.
- For hazardous chemicals, 10,000 pounds
What is a Hazardous Chemical?
Hazardous chemicals are substances for which a facility must maintain an MSDS (or SDS) under the OSHA Hazard Communication Standard, which lists the criteria used to identify a hazardous chemical. MSDSs (or SDSs) are detailed information sheets that provide data on health hazards and physical hazards of chemicals along with associated protective measures. Over 500,000 products have MSDSs (or SDSs), which are normally obtained from the chemical manufacturer.
Additional Important Compliance Deadlines
Important compliance dates are listed below. For handy reference, download our Environmental Reporting Deadlines line card.
- SARA Title III Tier II Reporting - March 1
- MAERS Reporting - March 15
- Greenhouse Gas (GHG) Reporting - March 31
- Toxic Release Inventory (TRI) Reporting - July 1
Need assistance? Gosling Czubak helps with hundreds of these reports each year and can assist you with Tier II regulations compliance. Contact us to learn more, we look forward to serving you!
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