Every year the due date for Tier II reporting is March 1. Tier II forms must be submitted by then to stay in compliance with EPCRA Section 312. Inevitably, however, many EHS teams in charge of environmental compliance and Tier II efforts wait until January or February to ask the question, “Are we on track?”
That timeframe rarely works out. Because instead of eliminating the risk of non-compliance, it elevates it.
The reality is, compliance and preparing for Tier II submissions is a year-round process. If you already follow that path to stay ahead of schedule, our compliments. But if you don’t, Encamp is here to help. We call it proactive environmental compliance.
Staying proactive spurs efficiency in your reporting preparations. It lets your EHS team focus on details and avoid the errors of rushing reports together at the last minute. And come March 1 every year, you submit Tier II forms on time, accurately, with the confidence of being in full compliance with EPCRA Section 312.
Tier II Reporting Resources and Best Practices
Consider the following resources and best practices as being fully experience based. Our reporting cred? For one, Encamp is the largest third-party filer of EPCRA Tier II reports in the U.S. For another, most of us at Encamp come from environmental compliance EHS consulting backgrounds, and we’ve filed thousands of EPCRA Section 312 reports.
That’s why we say staying proactive is the best approach.
Best practices
- Get everyone on the same path. From C-level directors to various program and facilities managers to EHS specialists and technicians, plus any contributors from throughout the business who gather and maintain data such as purchasing records and inventory information. Even when final reports fall to one or two persons, reporting is a group process.
- Provide structure with checklists and playbooks. Within a workflow for report preparation, every person should know what’s expected by way of their role, local and federal regulations, scheduled tasks, and internal deadlines ahead of March 1. Checklists and playbooks can further help ensure reporting accuracy by keeping details from slipping through the cracks.
- Throughout the year, meet often and communicate like clockwork. Hold weekly status and planning meetings to keep reporting preparation activities on the radar, including scheduling upcoming tasks and monitoring progress. Meet on-demand when something needs to be done or resolved right now.
- Set Tier II reporting goals per team member. Break the process into goals for each person and set deadlines for each goal. Team members should abide by playbooks and checklists when you have them.
- Share documents and work visibly. The first key is having an effective document storage hub in place. The second is creating an environment in which all users can access, review, and edit documents as a group. The Encamp platform makes this possible.
From Encamp’s Tier II Guide
The Tier II Guide ‒ A Practical Guide for Tier II Reporting includes details on who must report and how to comply. It also addresses common problems with things like mixtures and state reporting requirements. Other sections cover common reporting errors and the latest updates to state and federal requirements.
The Guide’s final section additionally offers these Tier II reporting tips.
- Download the Ultimate Tier II Checklist from Encamp. It’s free!
- Find out if your state has changed any of its reporting requirements, such as thresholds. Also see if the state has made changes to its reporting portal, LEPC contact info, etc.
- If your state requires files to be in the EPA’s Tier2 Submit format, download the newest version of the Tier2 Submit Software.
- Gather all associated purchasing records and other inventory information to compile your Tier II data.
- Ensure there are no new products to add to your inventory from last year. If there are, your state may require the Safety Data Sheet (SDS) to be submitted as well.
- Also check to see if you’ve stopped storing any chemicals so you can remove them from your reporting.
- If your state requires a site plan, be sure to update that if needed. Note any and all changes in chemical storage location or other requirements.
- Compare your Tier II report to last year’s and see if they’re similar in amounts and chemicals. If there are considerable differences, be sure to review those and make any necessary changes.
Transforming the way enterprises stay in compliance
Encamp is on a mission to create a world where good for business can equal good for the environment. We help enterprises transform compliance programs and human processes into a technology-driven system that lays the foundation for accurate and ongoing environmental compliance through a blended method of intelligent high-tech solutions and high-touch expert support.
Megan Walters
Megan is Encamp’s VP of Compliance & Customer Success and formerly a Senior Environmental Scientist. But she’s also a Certified Environmental and Safety Compliance Officer® (CESCO), an EHSMS Internal Auditor, a Certified Hazardous Materials Manager, eRailSafe certified, a HAZWOPER 40 Hour - Emergency Response Technician, and skilled in RCRA, DOT, and ISO 14001. Obviously, she knows “compliance.”
