Tier II Reporting Changes Effective for Calendar Year 2017 Reporting
Section 312 of the federal Emergency Planning & Community Right-To-Know Act (EPCRA or R-T-K) requires annual reporting of hazardous and extremely hazardous chemical storage. The intent is to ensure that emergency planners, responders, and citizens know about hazardous chemical storage at facilities. The report is referred to as the “Tier II” or “SERC” report and is an annual inventory of hazardous and extremely hazardous substances (EHS) stored by the subject facility. The report is due every year by March 1 and contains information assembled for the prior calendar year. The reports are sent to the State Emergency Response Commission (SERC), the Local Emergency Planning Committee (LEPC), and the fire department in the jurisdiction where the facility is located.
For the report due March 1, 2018, reporting requirements have changed. For each reportable chemical, facilities must identify their physical and health hazards. Until this reporting year there were 5 hazard categories:
- Sudden release of pressure
- Immediate (acute)
- Delayed (chronic)
For this and future reports, there are 23 hazard categories to be identified for each reported chemical, as shown below. This will require a fresh review of the safety data sheets for each reportable chemical to identify all applicable hazards. This process is expected to take more time than for previous reporting years. The information required can be obtained from Section 2 of the chemical’s Safety Data Sheet (SDS). A request for a new SDS may be needed to ensure the hazard information is up-to-date for Tier II reporting purposes.
New Hazard Categories
- Flammable (gases, aerosols, liquids, or solids)
- Gas under pressure
- Pyrophoric (liquid or solid)
- Pyrophoric Gas
- Oxidizer (liquid, solid or gas)
- Organic peroxide
- In contact with water emits flammable gas
- Combustible Dust
- Hazard Not Otherwise Classified (HNOC)
- Corrosive to metal
- Acute toxicity (any route of exposure)
- Reproductive toxicity
- Skin Corrosion or Irritation
- Respiratory or Skin Sensitization
- Serious eye damage or eye irritation
- Specific target organ toxicity (single or repeated exposure)
- Aspiration Hazard
- Germ cell mutagenicity
- Simple AsphyxiantHazard Not Otherwise Classified (HNOC)
Use of previous years’ versions of the Tier II Chemical Inventory Report Forms will not be acceptable for the March 1, 2018 reporting. Facilities must download new 2018 Tier II Reporting Forms (https://www.epa.gov/epcra/tier-ii-forms-and-instructions ) or use the new 2018 version of the Tier II Reporting Software ( https://www.epa.gov/epcra/tier2-submit-software ) for 2018’s submission.
EQM would be pleased to assist with your facility’s upcoming Tier II hazardous chemical inventory report preparation or simply to answer any questions you may have regarding the changes to hazard reporting.
Please direct any inquiries to Sandra Hance at 513-508-7236 or [email protected] in our Cincinnati office.