Idaho Tier II Reporting

Tier II reporting in Idaho is required for any facility that stores hazardous chemicals that meet or exceed chemical thresholds. Under Section 312 of the Emergency Planning and Community Right to Know Act of 1986 (EPCRA), submission of a Tier II form is required when working with hazardous chemicals. This form, known as the Emergency and Hazardous Chemical Inventory Forms, is used to notify state officials, local officials, and the general public regarding potential hazards.

Understanding Idaho’s Tier II Reporting Requirements

Who Needs to Report?

Any facility in Idaho that has hazardous substances equal to or greater than the established threshold amounts (listed below) must report.

• Any facility that stores 10,000 lbs or more of hazardous chemicals.
• Any facility that stores 500 lbs or more (or the threshold planning quantity, whichever is less) of extremely hazardous substances.
• Retail fuel stations with underground storage tanks need to report if they store:
• 75,000 gallons or more of gasoline
• 100,000 gallons or more of diesel fuel (all grades combined)

Key Points

• The reporting thresholds in Idaho apply to the maximum quantity stored at a facility at any one time. 
• Even if thresholds are met, chemicals with reporting exemptions do not need to be included
• Only facilities in Idaho meeting or exceeding the thresholds for at least one chemical must submit a Tier II report. Facilities below the thresholds for all chemicals are exempt.
• More information on Tier II reporting requirements in Idaho can be found here. 

Types of Facilities Subject to Tier II Reporting

Here are some examples of facilities and chemicals that would likely need to submit a Tier II report in Idaho if they meet the reporting thresholds:

• Food processing facilities – ammonia, chlorine, and other cleaning agents
• Lumber/wood product facilities – glues, resins, preservatives
• Chemical plants – a wide range of chemicals stored/used at the facility
• Mining operations – acids, solvents, explosives, diesel fuel
• Farms – pesticides, diesel fuel, fertilizers like ammonium nitrate

Key Points

Facilities in these industries would likely need to report common chemicals stored over Tier II thresholds like acids, flammable liquids, fuels, chlorine, and ammonia.

Need help sorting out tricky thresholds, exemptions, or submitting reports for sites or facilities in Idaho? Learn more here about how you can partner with Encamp to save you and your team time and hassle this reporting year.

Idaho’s Electronic Tier II Reporting System (Tier2Submit Software)

Overview of Tier2Submit Software

The Tier2Submit software is used for submitting regulated chemical inventory reports in Idaho. Facilities that store hazardous chemicals above threshold quantities are required to submit a Tier II Inventory Report annually under the Emergency Planning and Community Right-to-Know Act (EPCRA). The Tier II report provides information about the chemicals stored on-site to state and local emergency planning authorities.

How to Submit a Tier II Report in Idaho

Here are the key steps in submitting a Tier II report in Tier2 Submit Software:

• Download and install the latest version of Tier2Submit from EPA’s website.
• Open Tier2 Submit and create a new Tier II report for the facility.
• Enter all required facility identification, contact, and chemical inventory information.
• Validate the report data and resolve any errors.
• Certify and save the completed Tier II report as a .t2s file.
• Email the .t2s file to tier2@imd.idaho.gov to submit to the state.

Key Points

You must also send a copy of the Tier II report to the Idaho Office of Emergency Management at tier2@imd.idaho.gov, LEPCs, and the local fire department. A list of LEPCs and their preferred method to receive Tier II reports can be found here.

Deadlines and Timelines for Tier II Reporting

Annual Reporting Deadline

In Idaho, the Tier II reporting deadline is due March 1, annually regarding information on hazardous chemicals present at the facility in the previous calendar year.

Additional Reporting Requirements 

In addition to the annual Tier II chemical inventory reporting requirement in Idaho, there are some supplemental reporting situations that facilities must comply with:

• Initial Notification: Facilities must submit a notification within 90 days after they first exceed reporting thresholds for any hazardous chemicals on site. The thresholds for this notification are the same as the Tier II thresholds.
• Emergency Planning Notification: Facilities must submit a notification within 60 days after they bring an Extremely Hazardous Substance on-site in a quantity that exceeds its Threshold Planning Quantity.

Tips for Effective Tier II Reporting

Maintain Accurate Inventory Records

Starting early in collecting compliance data will help with making sure all the data is accurate and ready to go when the March 1st deadline comes around. A good rule of thumb is to have data ready to review the first week of January. 

Understand State-Specific Reporting Requirements

Although you can submit your report electronically in Tier2 Submit for Idaho, the LEPC and Fire Department do not have access to your report in Tier2 Submit. Therefore, you must file those reports separately. The Idaho Office of Emergency Management maintains a list of LEPCs with their contact information and how they like to receive the reports along with contact information for fire departments.

Keep Copies of All Submitted Reports

To save a copy of your Tier II report in Tier2Submit in Idaho after certifying your report, select “Save As” and choose a file name with your facility ID and report year. Save the file as a .T2S file type to your computer or external drive. Retain this electronic copy for at least 3 years along with your submission confirmation.

Common Mistakes in Tier II Reporting and How to Avoid Them

Incorrectly Estimating Quantity of Reportable Substances

It’s important to look at all chemicals across your equipment, departments, and processes. You also need to aggregate extremely hazardous substances that may exist at your facility in different capacities. For example, sulfuric acid could be stored in a drum. And if you have lead-acid batteries, you will need to take into account the sulfuric acid housed in the lead-acid batteries (if they are not exempt).

Misclassifying Substances

Be sure to check the EPA list of lists to double check if chemicals stored at your facility are an extremely hazardous substance (EHS).

Failing to Keep Up-To-Date with Changes in Regulations

Failure to report can result in Federal, state, and local penalties if an incident occurs and there is no Tier II report on file. 

Key Points

• Submit Tier II reports on time by the March 1 deadline.
• Ensure all hazardous chemicals above reporting thresholds are included.
• Completely omitting chemicals or the full report leads to the highest fines.
• Even small errors like one chemical can still incur sizable penalties.
• Follow EPCRA closely to avoid violations and protect your business finances.

Penalties for Non-Compliance with Tier II Reporting in Idaho

Potential Fines and Legal Consequences

Here are some potential fines and legal consequences for failing to accurately submit a Tier II hazardous chemical inventory report in Idaho:

• Fines up to $25,000 per violation per day
• Facilities may also be liable for EPA enforcement and corrective actions.

Impact on Community Safety and Emergency Preparedness

Here are some examples illustrating the importance of proper Tier II chemical reporting for community safety in Idaho:

• Fertilizer Explosion at Tramco Facility in Pocatello (2008)- The explosion at the Tramco fertilizer facility likely involved ammonium nitrate, a common ingredient in fertilizers. Ammonium nitrate is also a highly explosive compound when stored or handled improperly. Through adequate Tier II reporting, the chances of an explosion caused by mishandling or improper storage of ammonium nitrate could have been significantly reduced.
• Chlorine Gas Leak at Basic American Foods Plant in Blackfoot (2013)-  Chlorine gas is commonly used for water treatment and as a disinfectant in various industries. However, it is also highly toxic and poses a significant health hazard in case of leaks or releases. Proper Tier II reporting would have allowed authorities to know the quantities of chlorine and other hazardous chemicals stored at the Basic American Foods plant. By having clear information about the presence of chlorine gas and other hazardous chemicals at the plant, appropriate measures could have been taken to prevent leaks and minimize the risk of toxic gas exposure.