TIER 2 REPORTING CHANGES

Facilities that store or process hazardous chemicals that exceed the threshold amounts are required to submit a Tier 2 Hazardous Chemical Inventory Report to three agencies.

The next deadline is March 1, 2014.

What are the changes to the Tier 2 Report?


The U.S. EPA has added new required elements to the form and made changes to other areas of the form.
The changes include:
  • New reporting codes were added for chemical storage amounts;
  • New sections were added for reporting pure chemicals and chemicals found in mixtures;
  • Details must be provided to describe the storage container types and conditions;
  • The facility must indicate whether it is subject to Section 313 TRI reporting, EPCRA Section 302 reporting, and Section 112(r) of the Clean Air Act reporting for the Risk Management Program.

What impact will this have?


The completion of the Tier 2 Report will require additional time this year. Also, it is not known how quickly the IEMA will have the new form functioning on their reporting website and how effectively they will be able to respond to reporting issues as they come up.

Our professional staff is available to assess your situation and to prepare the necessary report. We have considerable experience in preparing this report for all facilities.

Todd P. Hedlund
[email protected]

LEAD/ACID BATTERIES ARE OFTEN OVERLOOKED
One of the most common Tier 2 reporting mistakes is not considering lead/acid batteries found in forklifts and backup power systems. The sulfuric acid in the batteries is an Extremely Hazardous Substance for both Tier 2 and EPCRA Section 302 reporting.


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