By March 1, certain facilities will be required to submit hazardous chemical inventory reports, commonly referred to as Tier II reports. In a recent webinar, Tier II Reporting, Strategies for Meeting Compliance Obligations Ahead of the March 1, 2016, Reporting Deadline, speaker Lori Siegelman, CIH, CSP, CHMM, of W&M Environmental Group, LLC, discussed who is impacted and what they must do to comply with Tier II reporting requirements under the Emergency Planning and Community Right-To-Know Act (EPCRA). If you missed it, this webinar will be presented live, again, on February 18.
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Tier II reports must be submitted annually by facilities that have any extremely hazardous substance (EHS) or other hazardous chemical on-site in quantities above established thresholds at any time during the reporting year. The reporting thresholds for EHSs are 500 pounds (lbs) or the threshold planning quantity, whichever is less. The threshold for all other hazardous chemicals is 10,000 lbs. Siegelman detailed these reporting thresholds, paying specific attention to what is considered a “hazardous chemical.”
Sielgelman explained that a hazardous chemical is defined by the Occupational Safety and Health Administration (OSHA), and that typically, if OSHA requires a safety data sheet (SDS) for the chemical, it must be included on the Tier II report unless the SDS specifically states “no hazard,” “Tier II reporting not required,” or something to that effect.