 State Differences and Tips for EPCRA Tier II Reporting Barbara Jo Ruble, President, Principal, QEP, CPEA, Baltimore, MD Federal, state, and local Tier II chemical inventory reports are due March 1 of each year, and now is the time to start getting ready.
Many states and even some municipalities have requirements for chemical inventory reporting that are different from or more stringent than the federal EPCRA Tier II rules. Some states and municipalities have lower reporting thresholds than federal EPA, while others require the use of state-specific forms or online reporting software (the California Hazardous Materials Business Plan and Inventory Statements are just one example). Even when states follow the federal EPCRA Tier II reporting rules, some local jurisdictions may enforce the Hazardous Materials Management Plan and inventory reporting requirements, which stem from the fire code (NFPA 1 Chapter 60.1 or IFC 2012 ed. Chapter 50.)
To stay compliant, it's important to research what your state and county/municipality require for hazardous material inventory reporting - every year. States frequently change requirements, especially regarding online reporting software, from year to year. Some reporting software systems require that you establish online IDs, which may require more lead time than signing up for an Amazon account. Starting at least two months in advance of the reporting deadline allows you time for mistakes and phone calls to technical support. In addition, since almost all jurisdictions require payments to be submitted along with the inventory reports, schedule time to get checks and payments authorized internally and double check the payment submittal addresses.
EPA has a web page with basic information on state Tier II reporting requirements and links to state websites for additional information and guidance ( http://www2.epa.gov/epcra/state-tier-ii-reporting-requirements-and-procedures). For local requirements, check your county or municipal code, which you can probably find online. Unless your site is in California, you will probably also need to contact your local fire marshal's office to find out if it requires a Hazardous Materials Management Plan and inventory reporting.
Once you compile your inventory information, it's a good time to check whether you have all the state, local, and fire code permits that are needed for hazardous material storage, aboveground and underground tanks, battery systems, and the like.
For more guidance on key state differences in EPCRA reporting requirements, attend STC's free webinar on Thursday January 29 at 2:00 pm (Eastern time). Space is limited, so register now!
Barbara Jo Ruble, QEP, CPEA is the President of Specialty Technical Consultants. She has more than 30 years of experience helping clients in a wide variety of industries to develop, assess, and improve their EHS management systems and compliance programs. Barb has performed more than 200 EHS compliance audits or management systems assessments of industrial facilities worldwide. She has also provided independent review of corporate EHS auditing programs. Barb is the primary author of OHSAS 18001/OSHA-VPP Occupational Health & Safety Management Systems: A Complete Implementation Guide, published by Specialty Technical Publishers of Vancouver, Canada.
For more information about STC's EHS auditing services or to discuss this article, contact Barb at bruble@stcenv.com or at 410-625-1952.
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