At the end of the calendar year, most facilities that store various types of hazardous materials start to look towards preparing their annual hazardous material report to State and local officials. Facilities often  refer to these as their “Tier 2 or Tier II” report. The question often comes up – should we be submitting a “Tier I” or a “Tier II” report?

EPCRA Section 312 includes a two tier approach. Tier I requires information (such as maximum amount of hazardous chemicals at the facility during the preceding year, an estimate of the average daily amount of hazardous chemicals at the facility, and the general location) be aggregated and reported by hazard categories. Tier II not only requires the information mentioned above, but also requests information on specific location and storage.

Tier I is required by Federal law; however, Tier II is required only upon request by the local emergency planning committee or the State emergency response commission. However, a covered facility may submit Tier II forms instead of Tier I forms. Because most States require submittal of Tier II forms, in practice a typical facility in the US will submit a Tier II form only, which satisfies both Federal and State reporting requirements.

Click here for more information on reporting under the Emergency Preparedness and Community Right To Know Act (EPCRA) and comparable State rules. Click here to review example Caltha projects on EPCRA and other reporting.

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