Encamp recently hosted a webinar on common Tier II reporting errors — and attendees came ready with great questions. Our experts Nikki Hatchett, Sales Engineer and former EHS professional, and Grace Kalivoda, Account Executive with eight years of hands-on EHS experience in oil and gas, answered them live.
If you’re preparing for next reporting season, this one’s for you. Here’s a look at some of the trickiest Tier II questions we heard — and what our team had to say.
Does Encamp Have an Inventory Template for Quarterly Audits?
We hear this one often. The short answer, yes. Encamp has built inventory audit templates for customers. We also have a chemical approval process flowchart that many teams rely on for quarterly reviews.
The real key is building a structured, repeatable process. This allows you to check your chemical inventory throughout the year, not just in January. Quarterly audits help you catch changes early: new chemicals arriving on-site, storage locations shifting, or quantities creeping toward thresholds.
Without a regular cadence, data gaps pile up fast. And by the time reporting season hits, you’re putting out fires instead of filing reports.
Want a copy of our template or flowchart? Reach out, we’re happy to share.
How Are Reporting Requirements Established for Temporary Facilities Like Construction Sites?
Temporary facilities can absolutely trigger Tier II reporting obligations. The rule is straightforward: if hazardous chemicals on your construction site exceed the reporting threshold on any single day during the year, a Tier II report (Section 312) is required. The same goes for the initial notification under Section 311.
The nuance is in who’s responsible. The agreement between the construction company and the site owner should spell this out before the project begins. If the site owner handles all Tier II reporting, the construction company’s chemicals may fold into their report. If the construction company is on the hook, they’re responsible for both the 311 notification and the 312 annual report.
As Grace shared from her refinery experience: turnaround and construction projects require careful upfront planning. The government expects chemicals above threshold to be reported, even if they’re on-site for a short time. You could be audited or face a spill on any given day — your report needs to reflect what was actually there.
Build reporting into your construction project scope from day one. Consider whether smaller tanks or quantities can keep you below threshold, and document your approach either way.
How Do You Know If You Need to Submit a Site Map?
Site map requirements vary by state. Start with your LERC guidance or your state environmental agency’s website. In many cases, the state’s Tier II reporting portal will include a required field for site maps, so the portal itself will guide you.
Beyond Tier II, some states also require site maps as part of a broader emergency action plan or hazardous materials management plan. Those may be separate submissions to your local emergency planning committee (LEPC) or fire department.
The bottom line: site maps aren’t a one-size-fits-all requirement. Each state sets its own rules. When in doubt, reach out to Encamp. We have access to all state documentation — and we can contact your LEPC directly to confirm exactly what’s expected.
What Should I Do If My Facility Coordinator or Emergency Contact Has Changed?
Update it now. Don’t wait for reporting season.
If your facility coordinator has changed, file an updated EPCRA Section 302 notification. Outdated emergency contacts are both a compliance risk and a safety risk. If something happens at your site, agencies and first responders need to reach the right person — fast.
In most cases, you can update contacts through the same state portal you use for Tier II submissions. Some states have slightly different processes, so check your state’s specific requirements.
Our recommendation: make verifying emergency contacts part of your annual post-submission checklist. Better yet, build it into your process whenever there’s a staffing change. An invalid name or phone number can lead to a notice of violation — or worse, a delayed response in a real emergency.
What Happens If a Facility Reported Last Year but Doesn’t Need to Report This Year?
This one gets overlooked more than it should.
If your facility filed a Tier II last year but didn’t have chemicals above threshold this year — maybe the site closed, operations changed, or you reduced inventory — many states still expect a closure report or formal close-out in the portal.
Without that closure, the state may flag your facility for not reporting and kick off an audit or follow-up inquiry. They see last year’s submission and wonder why nothing came this year. Silence isn’t a great answer.
Grace noted that Encamp handles closure reporting for customers in exactly this situation — including facilities like wellheads that open and close throughout the year. The takeaway: always close the loop in the portal, even when you have nothing to report. It’s a small step that prevents unnecessary scrutiny.
Tier II Doesn’t Have to Be This Hard
The questions from this webinar aren’t edge cases. Temporary facilities, contact updates, closure reports, inventory audits — these are the everyday details that can trip up even well-run programs when there’s no consistent process behind them.
That’s the value of year-round compliance management. When you build regular audits, structured data processes, and clear ownership into your program, reporting season becomes a routine checkpoint — not a scramble.
Since 2019, Encamp has submitted more than 63,000 Tier II reports on behalf of customers across all 50 states and territories. We combine powerful software with real human expertise to take the burden off your team.
Ready to simplify your Tier II process — this season and every one after? Get in touch with our team.
