With the end of the year approaching, many facilities will soon be reviewing the hazardous chemicals they store on-site to determine if they exceed the thresholds for Tier 2 reporting under EPCRA 312 (40 CFR 370) and equivalent State regulations. Local emergency response agencies can have additional hazardous chemical reporting requirements, in addition to Tier 2 reports.
The EPA rules that determine reporting requirements set out two options for determining thresholds. One requires much more detailed evaluation of materials stored on-site; the second requires less detailed analysis, but may result in additional materials being reported. Deciding which option is preferred for an individual reporting location will depend to a large degree on how chemical data are managed. Selecting the right option can safe a significant amount of effort for Tier II hazardous chemical reporting.
Caltha LLP provides technical support to facilities nationwide on chemical tracking and reporting.