With the increased focus on regulatory enforcement in today’s environment, companies are under constant pressure to stay informed of new and changing regulations, while at the same time facing staffing cutbacks and budgetary restrictions. The stress of impending fines for non-compliance looms large over the heads of small, medium and large businesses alike.
Outsourcing reporting tasks is a natural alternative for many regulatory reporting requirements. VelocityEHS ChemTel regulatory specialists will assist our clients evaluate hazardous materials inventories and facility diagrams to determine reporting requirements.
Tier II Reporting
VelocityEHS ChemTel is adept at filing Tier II reports in all 50 states. Our reporting services streamline and simplify the Tier II reporting process and provides a valuable solution for clients with multiple facilities and limited EH&S staff. An added benefit is the centralization of client’s regulatory reporting. Our technical department will assist in the compilation of your data in order to ensure accuracy and integrity in the reporting process.
Frequently Asked Questions Regarding Tier II Reports:
Who must report?
If you store, use or produce chemicals, requiring maintenance of Safety Data Sheets (SDS) under the Hazard Communication Standard, that are present in your facility in excess of the appropriate threshold, and are not exempt under Title III, then you must submit Section 311 and Section 312 (Tier II) reports.
What is a "reportable chemical"?
As defined by the EPA, a "reportable chemical" refers to hazardous chemicals and extremely hazardous substances present at your facility in excess of the relevant reporting threshold and not exempt under Title III.
How do I determine the "maximum amount"?
You must consider the daily (weekly, monthly) amounts (in pounds) of each reportable chemical at your facility. The amounts should vary as shipments increase your inventory and regular use depletes it. The "maximum amount" occurs for each chemical when its storage level reaches its highest point for that year. Reporting thresholds depend on the "maximum amount.”
How do I calculate the "average daily amount"?
Weights of reportable chemicals may be measured daily, weekly, or monthly as appropriate to your type of operation. For every reportable chemical, consider the number of days (weeks, months) that chemical is at your facility and compute its daily (weekly, monthly) storage weight. Then total these numbers and divide by the number of days (weeks, months) the chemical is on-site.
How specific must I be in reporting "general location"?
Is a site plan necessary?
For the Tier II form, you must indicate at least the building, lot, warehouse, shed, tank, field, etc. where the chemical is stored. On the Tier II form, where practical, the specific room in a building or quadrant of a field should also be noted. The EPA also recommends that you use a site-plan to indicate where chemicals are stored at your facility. Simply copy the facility plans and mark all appropriate storage areas for your reportable chemicals. Show all symbols and abbreviations in a complete, clear notation key.