JANUARY – FEBRUARY
Reporting Period
January to February: Report Submission
The next phase marks the official start of Tier II season leading up to the March 1st submission deadline. During this time, proactive EHS teams have already successfully collected the right data and are ready to submit complete reports per facility with the exact requirements across all federal, state, and local jurisdictions.
Because each facility’s environmental data has been collected and centralized prior to Tier II season, EHS teams now have the months of January to February to review their chemical inventory to verify contact information, determine accurate reporting thresholds, and update any new site plan or SDS requirements needed by the regulatory body.
Questions to Ask Yourself & Your Team
- Is everyone on the contact list still employed there and/or appropriate for this report?
- Has the facility introduced any new chemicals in the past year?
- Have there been any major changes in process or personnel this year? How could that affect my Tier II report?
- Who would be a good onsite resource to double-check the report and look for gaps?
Checklist
- The first step is gathering purchasing information and inventory to make sure new chemicals or quantities are captured.
- Equally important is verifying that the facility or emergency contact information listed on your reports are also up to date. As the main point of contact for SERCs, LEPCs, and the Fire Department, it is crucial that this personnel information is regularly updated for emergency and non-emergency correspondence.
- Review your existing chemical inventory and add any new chemicals that exceeded reporting thresholds. Additionally, remove chemicals that were no longer on site the previous year or no longer exceed reporting thresholds.
- Compare your reporting data from the previous year to make sure all hazardous chemicals that require an emergency notification are accounted for.
- Update and upload any new documents such as site maps and SDSs.
Regularly updated site maps and SDSs contain vital information about hazardous chemical substances and how to safely handle them, further protecting your community and the environment from catastrophic events.
- Once you’ve inputted your facility environmental data into the required reporting format of each regulatory body, stakeholders must verify the information before submission.
Pro Tip: Developing a robust review process will reduce the risks that data is omitted or that incorrect information is reported.
- Finalize the Tier II report for submission and are going to the appropriate regulatory body.
- Submit the Tier Report to the SERC. To check the reporting procedure and requirements for your state visit the EPA’s State Tier II Reporting Requirements.
- If applicable to your state or locality, submit a copy to the LEPC and Fire Department. Some states require submitting directly while some states will take care of those submissions for you. Please check with your SERC.
- Pay the filing fees associated with your Tier II report. State portals accept payment fees directly, whereas other states send your facility a bill and require you to pay by check or credit card.
Fee amounts vary based on a state’s criteria. For instance, states including Louisiana, Minnesota, and Pennsylvania bill your facility per each chemical being reported. Other states, like New Jersey, bill the facility by the number of employees.
- Add any confirmation emails, receipts, or proof of mailing you received to your records. This will demonstrate that you successfully submitted your report in case of audits.
Pro Tip: Digitize all your records to make them easily accessible anywhere and anytime during audit inspections.
- Check for new or updated exemption applicabilities that exclude filing Tier II reports for certain chemicals and thresholds.
EVERGREEN TASKS (IMPORTANT EVERY MONTH)
- Confirm local, state, or federal requirements haven’t changed.
- Review and update site plan.
- Review emergency contact information; file required EPCRA 302 notification if the facility emergency coordinator has changed.
- Contact State Emergency Response Commission (SERC) to clear up any questions prior to reporting period.
Point of Interest
Print out the site plan map for each facility and clearly indicate the locations of all chemicals. This tells first responders precisely where each chemical material is stored and at which location, since companies sometimes have different facility locations within the same county.
