Tier Two. Almost due. So, what’s new?

Changes to Tier Two Hazardous Chemical Inventory reporting requirements are now effective!

On July 13, 2012, EPA published a final rule to revise Tier I and Tier II reporting forms, as well as the Confidential Location Information Sheet. The revisions added some new data elements and revised some existing data elements.

The rule became effective on January 1, 2014. Facilities must comply with the new requirements on the Tier II inventory form for reporting year 2013, which is due by March 1, 2014. (Note that your state may have specific requirements for reporting and submission the Tier II inventory form and/or the state reporting form or format. Contact T. Cozzie Consulting or your state for information on state specific reporting requirements.)

The reporting requirements under the community right-to-know provisions of EPCRA sections 311 and 312 are on-going obligations. These requirements apply to owners and operators of facilities that store hazardous chemicals in quantities at or above reporting thresholds specified in 40 CFR part 370. Under EPCRA section 312, if a hazardous chemical is present at or above the reporting threshold , the facility owner or operator is required to submit an emergency and hazardous chemical inventory form (Tier II or state equivalent, as no states currently accept the shorter Tier 1 form) to the SERC, LEPC and the local fire department by March 1 annually.

Changes to the reporting requirements that take effect for the 2013 reporting year include the following:

Chemical Information on Tier 2 Form

Paper copy of the Tier 2 Form – Does anyone actually use this anymore?


The final rule requires that facilities report new mandatory data elements:

  • facility latitude and longitude;
  • identification numbers assigned to facilities subject to Toxic Release Inventory (TRI) and Clean Air Act Section 112(r) risk management program (RMP) requirements;
  • if the location where the hazardous chemicals are stored is manned or unmanned; and
  • instead of the number of full-time employees, report the maximum number of occupants that may be present at the facility at any one time.

The rule requires that facilities provide contact information for the facility emergency coordinator and Tier II contact, as well as email addresses of the owner or operator and emergency contact(s).

This final rule added separate data fields for reporting pure chemical and mixtures in the chemical reporting section of the Tier II inventory form. In addition, the final rule requires facilities to provide a description for the storage types and conditions rather than reporting codes.

The revised Tier II inventory form also includes the table of range codes and amounts for reporting maximum amount and average daily amount.

EPA decided not to require the facility phone number, but includes it as an optional data element on the revised Tier II inventory forms. Likewise, the parent company contact information is not required, but is included as an optional data element on the revised inventory forms.

Finally, the 2012 rule revises the Tier II inventory form for facilities to report any additional State or local reporting requirements or to voluntarily report hazardous chemicals below the reporting thresholds.

Contact T. Cozzie Consulting for further information or assistance. You can find additional reporting guidance and links to reporting tools HERE or through the EPA EPCRA Tier I and Tier II Reporting webpage.