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Does our company need to submit Tier II reports? If so, how do we start?

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If your facility has hazardous chemicals onsite, the Occupational Safety and Health Administration (OSHA) stipulates you must have a safety data sheet. Additionally, if certain thresholds are exceeded, a Tier II form must be submitted annually.

According to Lauren Taylor, a Senior Environmental, Health and Safety (EH&S) Consultant with PROtect, “The thresholds are typically 10,000 pounds unless you have an extremely hazardous substance and then the thresholds are typically 500 pounds or the federal reportable quantity, whichever is less.”

The purpose of the Tier II form is to provide State, local officials and the public with specific information on potential hazards. This includes the locations, as well as the amount, of hazardous chemicals present at your facility during the previous year.

Timeframe and State Requirements

Facilities may be required to submit initial reports within a short time period of the chemical being brought on site, and then the reports are due annually on March 1.

According to the Environmental Protection Agency (EPA), “Some states may have specific requirements for reporting and submission of the Tier II inventory form and/or the state reporting form or format.”

You can check state-specific reporting requirements here: https://www.epa.gov/epcra/state-tier-ii-reporting-requirements-and-procedures

How PROtect Can Help

The PROtect environmental staff provides services related to ongoing operational obligations. In addition to assistance with Tier II annual reporting, they have expertise related to:

  • Air Emissions Inventory
  • Toxics Release Inventory (TRI) Reporting
  • Greenhouse Gas Annual Reporting
  • Fuel Additive Manufacturer Annual Reporting
  • Toxic Substances Control Act (TSCA) Chemical Data Reporting
  • SPCC Plan Review and Updates (including P.E. Certification)
  • FRP Review and Updates
  • RMP 5-Year Updates
  • Hazardous Waste Assistance
  • Permit Maintenance and Management
  • Regulatory Required Notifications
  • 12-Month Rolling Documentation Development
  • Emission Testing Coordination
  • Post-Inspection Negotiation and Response Assistance
  • Representation During EPA and State Inspections
  • Environmental Training
  • RFS2 Engineering Review – 3 Year Re-registration
  • Temporary and Part-Time Staffing

Contact PROtect directly at (316) 927-4290 to discuss how we help chemical facilities ensure compliance and safety.

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