Tier II Reporting Tips: Lower State Thresholds

At Encamp, Tier II reporting is our specialty. And one of the most common things we see when reviewing Tier II data for our customers is that it’s critical to collect quantity data on all hazardous chemicals onsite.

Without staying up-to-date on your state’s threshold requirements, it’s easy to overlook chemicals that are stored in smaller quantities, resulting in an incomplete and noncompliant report.

While most States follow the federal EPCRA 312 reporting thresholds, other States require much smaller amounts of all chemicals and not extremely hazardous substances (EHSs). In several states, the thresholds to trigger Tier II reporting are exceptionally low, so even small quantities of hazardous or extremely hazardous substances need to be collected and up-to-date as reporting season approaches.

The following States have much lower threshold planning quantities (TPQs) than the standard 10,000 lbs for hazardous materials and 500 lbs or less for extremely hazardous materials (EHSs). 

• California
  • Thresholds (ALL CHEMICALS): Solids- 500lbs, Liquid- 55gals, and Gas- 200cu ft
    • Regulations
• Delaware
  • Thresholds: Hazardous Materials- 500 lbs or 55 gals. EHS- 500 lbs or 55 gals or TPQ, whichever is less.
    • Regulations
• Louisiana 
  • Thresholds: Hazardous Materials- 500 lbs or 55 gals. EHS- 500 lbs or 55 gals or TPQ, whichever is less.
    • Regulations
• Missouri*
  • Thresholds: Explosives and Blasting Agents- 100 lbs and must be reported to the fire department within 24 hours of being at the facility.
    • Missouri Tier II Instructions
• Oregon 
  • Thresholds: Hazardous Materials and EHSs- Solids: 500 lbs, Liquid: 500 gals, Vaporous Gas: 500 Cu ft., Liquefied or cryogenic gas: 500 gals
  • Thresholds: Highly toxic substances or explosives- Liquid: 5 gals, Solid: 10 lbs, Gas: 20 cu ft.
    • User Manual
• Vermont
  • Thresholds: Hazardous Materials and EHSs- 100 lbs or the TPQ, whichever is less
    • Vermont 2022 EPCRA Tier II Package

*Missouri requires federal reporting thresholds for all other chemicals besides explosives and blasting agents.

We hope these insights help keep you on track this Tier II season. If you could still use additional support, reach out to us.

As the largest third party Tier II filer, Encamp solves the complexity of environmental compliance with high-tech solutions and high-touch expert support. We help top organizations maintain accurate and ongoing compliance through centralized data, visibility across all facilities, actionable reporting insights, and top-tier expert support.