Environmental Compliance Tier II Reporting Tips – Deadline this March 1st

 by: Wendy Tindall, CPEA

As part of a new series, Bay West's environmental compliance expert, Wendy Tindall, offers readers insights on highly relevant environmental compliance topics. Ms. Tindall has over 17 years’ experience working on environmental compliance services, including extensive regulatory expertise in air, waste, water, and tank regulations, permitting and reporting.

Tier II Reporting – Deadline is March 1st, 2019 for Calendar Year 2018

Title III of the federal Superfund Amendments and Reauthorization Act (SARA) is referred to as the Emergency Planning and Right-to-Know Act (EPCRA). EPCRA established requirements for federal, state, and local governments, American Indian Tribes, and industry regarding emergency planning and reporting on hazardous and toxic chemicals. There are four main provisions of EPCRA program:

  • Emergency Planning (Section 302)
  • Emergency Release Notification (Section 304)
  • Hazardous Chemical Storage Reporting Requirements (Section 311/312) – TIER II Reports
  • Toxic Chemical Release Inventory (TRI) (Section 313)

Under Section 312 of SARA Title III, facilities are required to submit an annual Tier II report by March 1 for the previous reporting calendar year if they:

  1. Store Extremely Hazardous Substances (EHS’s) at 500 pounds or the Threshold Planning Quantity (TPQ), whichever is less.
  2. Store 10,000 pounds or more of any hazardous chemical that requires a Safety Data Sheet (SDS) under the OSHA Hazard Communication Standard

The Minnesota EPCRA Program is responsible for the collection and maintenance of Tier II data reported by Minnesota facilities. Tier II reports provide state and local officials with specific information on hazardous chemicals present at your facility for use in emergency preparedness planning. Check out the link below for a step-by-step training video on how to use the Minnesota Online Tier II Manager software to submit your 2018 Tier II Report:

Minnesota Division of Homeland Security and Emergency Management Online Tier II Manager™ Training Video

Also, links to other upper Midwest State Tier II Reporting Contacts and Requirements are shown below:

click map

Tier II Reporting Requirements - North Dakota

Bay West post - Tier II Reporting Requirements - Nebraska

Bay West post - Tier II Reporting Requirements - Minnesota

Bay West post - Tier II Reporting Requirements - Wisconsin

Bay West post - Tier II Reporting Requirements - Michigan

Bay West post - Tier II Reporting Requirements - Michigan

Bay West post - Tier II Reporting Requirements - South Dakota

Bay West post - Tier II Reporting Requirements - Iowa

For more information on the list of EHSs and their TPQs review the SARA Title III Information Packet. Bay West has environmental compliance technical experts to assist you with determining your requirements and submitting your Tier II report to the appropriate state agency. Please contact me (Wendy Tindall) at wtindall@baywest.com or 651-291-3467 for more information.

 

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