Tier 2 & Form R Reporting

TIER 2 HAZARDOUS CHEMICAL INVENTORY REPORT


Under the SARA Title III, Community Right-to-Know Act, owners or operators of facilities that have hazardous chemicals on hand in quantities equal to or greater than set threshold levels must submit either Tier 1 or Tier 2 report forms by March 1st of each year. The completed forms are to be submitted to the local fire department and to the County and State Emergency Planning Agencies. Specifically for Illinois, the Illinois Emergency Management Agency (IEMA) demands that the Tier 2 form be used for all reporting. Illinois requires that the filing of the report with all attachments is through the state's IEMA website.

All submitted Tier 2 report forms continue to take on increased importance as many local fire departments are updating their electronic records to document the amount of extremely hazardous substances stored in their geographic response area. Additionally, county emergency response agencies, through coordinated efforts with local fire departments, are upgrading sophisticated emergency response plans to handle chemical spills and releases in their areas.

Common chemicals such as ammonia, freon, gasoline, fuel oil, and sulfuric acid in fork lift batteries are frequently overlooked by facilities, but are still very much subject to reporting. Many companies have been fined by the United States Environmental Protection Agency (U.S. EPA) for failing to report these frequently missed common chemicals.

SPECIAL REPORTING UNDER EPCRA SECTION 302
If a facility brings an Extremely Hazardous Substance on-site in a quantity that exceeds its Threshold Planning Quantity (TPQ), it must submit a Section 302 Notification within 60 days.

The facility must also provide notice to the Local Emergency Planning Committee of any changes that may be relevant to emergency planning, within 30 days of the change. This includes: moving the substance to a different location, the substance is no longer present, or the facility is no longer in operation.

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FORM R - TOXIC CHEMICAL RELEASE INVENTORY REPORT

Form R – the Toxic Chemical Release Inventory (TRI) Report -- is a comprehensive annual report that documents the use and release of toxic chemicals that are commonly used in industry. This requirement is identified under Section 313 of the Federal Emergency Planning and Community Right-to-Know Act (EPCRA). The deadline for submittal of the annual Form R Report is July 1st.

Of all the annual Federal and State EPA compliance reports required of industry, the TRI reporting deadline is possibly the most aggressively enforced. The Chicago office of the U.S. EPA is involved in widespread enforcement of this regulation, with fines.

Admiral can conduct a thorough evaluation of your operations to identify toxic chemical usage, and determine if a TRI report is required. If a Form R Report is required, our professional staff has the expertise and experience to quickly and efficiently prepare all of these forms.

With Admiral's extensive experience in a wide range of industries and facilities, our professional staff is well versed and available to assess your reporting needs and can easily prepare the necessary reports.

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