Staying Compliant: Five Common Errors with EPCRA Tier II Reporting

While accurate Tier II reporting is crucial for providing local emergency responders with the information they need, preparing these reports can be a major undertaking for EHS professionals. At Encamp, we have assisted customers with thousands of successful Tier II filings and understand the common pitfalls. Leveraging our blended high-tech and high-touch solutions, we empower organizations to maintain EPCRA compliance with ease.

We recently hosted a webinar entitled EPCRA Tier II Reporting: Avoid Common Errors to Improve Compliance for the 2023 Reporting Season with Madison Martin, Technical Program Manager at Encamp, and Julie Ragains, VP of Customer and Data Solutions at Encamp to help teams prepare for the fling season ahead.

To help your facility stay on top of Tier II requirements, we’ve put together a summary from the webinar of the 5 most frequent errors we see, along with tips to avoid them:

1. Incomplete or Missing Information

It’s critical to report complete and accurate information about the chemicals stored onsite. Some of the most commonly missed details include:

• Exact chemical names – Don’t rely on abbreviations or best guesses. Utilize the SDSs for each chemical to ensure accuracy.
• Quantities – Nail down your max and average amounts for the most precise report.
• Equipment – Don’t forget that operational equipment like forklifts could contain reportable chemicals in batteries or fuel tanks. The Encamp solution has a “finished goods” feature, which allows managers to quickly account for and track these easily overlooked items.

2. Miscalculated Thresholds

Double-check that you are reporting pursuant to the correct thresholds. Under-reporting is a common issue, as is failing to aggregate similar Extremely Hazardous Substances (EHSs) to determine if thresholds are met. Don’t forget to convert chemicals from gallons to pounds if required by your state. Encamp automatically tracks chemical inventories against federal and state thresholds, alerting users when they’ve been reached, in order to prevent these errors.

3. Missing or Inaccurate Contact Information

Emergency responders rely on your contact information in the event of an incident, so ensure it is complete and correct to keep them safe. List contacts who are knowledgeable about the facility and available 24/7. Follow up with local emergency response teams so they know who to reach in an emergency.

4. Vague Storage Location Descriptions

Storage location details should be clear enough for anyone to easily identify. Use directional cues and landmarks within the facility. Pinpointing locations on the required site map is also essential. Some states like Nevada even require the exact latitude and longitude of the storage location. 

5. Missing State-Specific Requirements

Over a dozen states have thresholds lower than federal requirements including CA, DE, LA, NJ, NC, OR, and VT, so be sure to follow the most stringent rules. Some states also require additional details like transportation and receipt information in the Northeast or EHS planning data in AZ and KY. Know your state! If you have questions about states you need to file in, utilize Encamp’s State-by-State Guide to EPCRA Reporting.

Transforming the Way Enterprises Stay in Compliance

Tier II reporting doesn’t have to be a headache. Taking the time to prepare in advance, thoroughly tracking inventory, and being aware of state regulations can save you time – and potentially your reputation – in the future. Leveraging the Encamp solution can help you avoid common mistakes and keep your facility compliant. Request a demo with us today to learn how you can easily manage your facility compliance data, tasks, reporting, submissions, fee payments, and record-keeping — in one place.