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: