It’s Beginning to Look a Lot Like…Tier II?

With the end of the year rapidly approaching and people counting down the days to a nice holiday break, some facilities are even counting down to an end of the year shutdown. For many, there are a lot of things to take into account and it may go without saying that Tier II is probably not one of them. A large portion of those responsible for Tier II reporting wait until after the holiday season (Jan. 1) to begin thinking about Tier II, but I would offer that now is a great time to begin making sure that the necessary information to complete Tier II reporting is available (once you are back from the holiday of course and 2018 has officially come to a close). Since Tier II is one of those activities that comes once a year, here is a refresher on what is reportable and how reporting works.

What is reportable?

There are two groups of chemicals that are reportable under the Federal requirements for Tier II (found at 40 CFR 370):

Extremely Hazardous Substance (EHS) – This is a finite list of substances defined by the EPA (found at 40 CFR 355 appendices A and B)

-AND-

Hazardous Chemicals – These are materials for which an SDS is required to be maintained under OSHA requirements. A threshold of 10,000 lbs is applicable for these chemicals. For gasoline or diesel fuel at a retail gas station, there are potentially different thresholds if certain conditions are met.

There is another point of interest to consider for the Hazardous Chemicals group. Facilities have the option to decide how to determine if the threshold quantity is met for these chemicals – they can add all instances of every substance together and report on that quantity OR they can consider the total quantity of each mixture separately. This is a business decision for organizations and one that is good to consider now so you can begin collecting the necessary information.

For Alaska, California, Delaware, Louisiana, Missouri, Nevada, New Jersey, Oregon and Vermont, what is reportable is more comprehensive than what is described above. For all states, please be sure to consult your state’s requirements for full information.*

How does reporting work?

Reports are due every year by March 1. In addition to determining if there are additional requirements for what is reportable beyond what is defined by the Federal EPA, each state also determines how reports are submitted. The EPA has the Tier2 Submit software available and some states accept information via that platform, but more and more states continue to move away from using it to collect the required information. Some states use a tool called e-Plan, which accepts a Tier2 Submit file, and a growing number use a different state-specific reporting platform or submission method. SiteHawk has an infographic and corresponding video that provides an overview of how reporting works for your state. The infographic also has a link to each state’s website where more information on state-specific reporting requirements for what is reportable and how to actually submit the reports to the appropriate entities (SERC, LEPC and local fire department) can be found.

What can you do to prepare?

Regardless of the specifics for what is reportable for your facility (or facilities), the way to prepare all starts with the same tasks – understand what is reportable onsite and identify how you are going to submit your report(s).

  • Identify materials that contain EHSs (an electronic system that cross-references the list against the composition/ingredients of all chemicals onsite is ideal to help with this)
  • Determine the hazardous chemicals that may need to be reported
  • Make a decision on how to determine what hazardous chemicals are reportable and which reporting method is to be used (report at the mixture level using mixture quantities OR report at the substance level aggregating all substance quantities for each unique substance)
  • Determine where and how the location and quantity information is stored for your materials
  • Consult your state’s agency/requirements to ensure you have a current understanding of what is reportable and how to file your report

As with any big event, like the holidays or Tier II, early preparation is key to successfully navigating the season. Don’t wind down just yet! Get ready because it’s beginning to look a lot like Tier II. #Tistheseason4TierII

 

* Based on information from March 2018.