Common Mistakes in Tier II Reporting

It is important to afford yourself enough time to prepare your Tier II reports and submit them according to your state’s requirements. While many states want you to use the U.S. Environmental Protection Agency’s (EPA) Tier2 Submit software for filing your Tier II information, some states and local agencies have different requirements. Be sure to check with your state or local agency on how it wants the report submitted.

Some states now accept (or require) submissions via E-Plan, an emergency response information system developed by the University of Texas at Dallas.

E-Plan has compiled a list of the seven most common errors found when submitting Tier II reports via its system:

1. Missing county name. Many facilities fail to provide the correct county name. E-Plan requires a valid county name reported for each facility.
2. Missing North American Industry Classification System (NAICS) code or Dun and Bradstreet number. E-Plan notes that the EPA allows nonbusiness entities to enter “N/A”.
3. Incorrect or not reporting latitude and longitude coordinates.  E-Plan requires that you report the facility’s latitude and longitude coordinates in decimal degrees or select their “Lookup Lat/Long” option, which will convert your facility’s physical address to latitude and longitude coordinates via geocoding.
4. Not reporting owner/operator. The EPA requires an owner/operator with full name, mail address, and phone number.
5.  Not reporting emergency contact or 24-hour phone for emergency contact. The EPA requires one Emergency Contact with full name and 24-hour phone number.
6. Not reporting a CAS number. You must enter 0000 for any chemical for which you do not have a Chemical Abstracts Service (CAS) number.
7. Not reporting state data. Some states have additional reporting requirements beyond the requirements of federal Tier II reporting requirements. Currently, 28 states have additional data Tier II fields.

Changes to Tier2 Submit

If you are using EPA’s Tier2 Submit software, be aware that the following changes have been made to it for reporting year 2016:

• Modified import to also allow Tier II data to be imported using an XML file that adheres to the new national data standard
• Modified export to also create an XML file that adheres to the new national data standard
• Added “Date Signed” to the Advanced Search
• Updated the Chemical Inventory links in the Tier2 Submit-generated KML files
• Resolved an issue where large files could not be imported in Windows^®
• Updated state-specific fields
• Revised helps
• Made additional minor changes and bug fixes

In tomorrow’s Advisor, we will review penalties for faulty Tier II reporting.