What is EPCRA Tier II Reporting?
EPCRA Sections 311 and 312 mandate that facilities storing hazardous chemicals must submit a Tier II form to their State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC), and local fire department.
Reports cover the maximum amount of chemicals present at the facility at any one time during the preceding calendar year, with submissions due annually on March 1st.
Standard Threshold for Hazardous Chemicals
For the vast majority of hazardous chemicals, the reporting threshold is 10,000 pounds. A 'hazardous chemical' in this context broadly refers to any chemical for which a facility must maintain a Safety Data Sheet (SDS) under OSHA's Hazard Communication Standard.
Common examples include bulk storage of diesel fuel, gasoline, propane, oils, and large quantities of raw manufacturing materials.
Thresholds for Extremely Hazardous Substances (EHS)
The EPA maintains a specific list of Extremely Hazardous Substances (EHS) found in 40 CFR Part 355 Appendix A. These chemicals pose severe acute health effects and have much lower reporting thresholds.
The Tier II reporting threshold for an EHS is 500 pounds OR the chemical's specific Threshold Planning Quantity (TPQ), whichever is lower. For example, Sulfuric Acid has a TPQ of 1,000 lbs, so its Tier II threshold is capped at 500 lbs.
How to Calculate Chemical Inventory for Thresholds
You must calculate the maximum daily amount of a chemical on-site to check against the threshold. For mixtures, you can evaluate the entire mixture as a whole, or calculate the exact weight of the hazardous component within the mixture.
Calculation Example: A facility has a forklift fleet using lead-acid batteries. The batteries contain sulfuric acid (an EHS). You must determine the total weight of sulfuric acid across all batteries present on the heaviest day of the year. If the total exceeds 500 lbs, it must be reported.
Frequently asked questions
Do I have to report office supplies or consumer products?
No, EPCRA includes exemptions for consumer products used in the workplace in the same manner and frequency as a normal consumer would use them.
What is the Tier II reporting threshold for retail gas stations?
Retail gas stations have higher thresholds if all fuel is stored in compliant underground storage tanks: 75,000 gallons for gasoline and 100,000 gallons for diesel fuel.
How do I calculate the weight of a liquid chemical?
You multiply the volume in gallons by the specific gravity of the chemical, and then multiply by 8.34 lbs/gallon (the weight of water) to find total pounds.
If I only hit the threshold for one day, do I still report?
Yes. If the amount of the chemical present at your facility meets or exceeds the threshold on any single day during the calendar year, it is reportable.