Section 312 of the Emergency Planning Community Right-to-Know Act, or EPCRA, of 1986 requires companies that work with hazardous materials or dangerous chemicals submit annual reports to their State Emergency Response Commission, Local Emergency Planning Committee, and local fire departments. These reports are the Emergency and Hazardous Chemical Inventory Reports, also known as Tier II reports, and they must be submitted by March 1st every year. Is your company ready to submit your Tier II report? Here’s why it is critical for your business.
What Constitutes a Tier II Report?
The annual Tier II report involves taking the time to carefully review your work facility, determining the quantity of chemicals stored at the site, and understanding whether these quantities need to be reported. For any hazardous material that has a Safety Data Sheet, any with quantities on-site of 10,000 pounds or more needs to be reported on your Tier II report. In addition, any substances that are categorized as Extremely Hazardous Substances (EHS) has a reporting threshold of 500 pounds or more. The Tier II report must include information about all hazardous materials present at your facility during the previous calendar year that exceeded these thresholds.
Why is it Important to Submit a Tier II Report?
Regulations make the submission of a Tier II report mandatory for companies that handle hazardous materials and strict civil penalties are levied on companies that do not comply with these regulations. A violation can result in a civil penalty of up to $25,000, and every day that a violation continues constitutes a separate violation for each day. So the costs of not submitting your Tier II report on time can be devastating to your company.
In addition, the proper preparation and submission of this report is critical to civil agencies if an emergency should occur at your facility. It gives these civil authorities the ability to properly plan and prepare for emergencies and allows for a more well-organized and effective response, limiting liabilities and injuries during a response effort.
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