Guidance in Completing the Tier II Chemical Inventory Report

In 1986, Congress reauthorized and amended the Hazardous Waste Superfund Clean-up Regulations (a.k.a. SARA). Title III of SARA created the Emergency Planning and Community Right-to-Know Act (EPCRA), which required industrial facilities to provide information to the:

    * Local fire fighters regarding the chemical hazards at your facility in the event that they must respond to a fire;
    * Local Emergency Planning Committee so they can adequately prepare an emergency response plan for the community; and
    * People in the community because they have a right-to-know the chemical hazards in their community

The report is known as the Tier II Chemical Inventory Report and is due March 1st of every year. The Tier II report must be submitted to the State Emergency Response Commission, the Local Emergency Planning Committee, and to the fire department with jurisdiction over the facility. It is important to note that some states and local agencies have different rules, fees, and unique forms so it is necessary to contact the local emergency response agency for information for your locality.

The Tier II report requires the following information:

    * Facility information such as address, SIC code and the names of people who would be responsible in the event of an emergency at this facility and their 24-hour phone numbers;
    * Chemical information such as, the chemical name, CAS No., the physical state of the chemical (solid, liquid, gas), pure chemical or a mixture, the physical and health hazards (fire, reactive, sudden release of pressure, or immediate or delayed health hazards);
    * Inventory quantities such as the average, maximum quantity and the number of days per year;
    * Storage conditions, such as the type of container, temperature and pressure; and
    * Storage location, preferably a location description that is related to an attached site plan.

Additionally, the EPA has created a list of “Extremely Hazardous Substances” that must be reported on the Tier II, if stored above the threshold planning quantity. The Extremely Hazardous Substances (EHS) and their threshold planning quantities are listed in the Title III Consolidated List of Lists. This list and additional instruction for Tier II reporting is accessible at:

http://yosemite.epa.gov/oswer/ceppoweb.nsf/content/tier2.htm