EPA Adds New Data Elements to Tier I and Tier II Forms Required by EPCRA
The Emergency Planning and Community Right to Know Act (EPCRA) provides for emergency planning and preparedness, emergency release notification reporting, community right-to-know reporting, and toxic chemical release reporting. Facilities that have hazardous chemicals on-site above regulatory thresholds must provide local planning and preparedness agencies with an emergency and hazardous chemical inventory form, known as a Tier I or Tier II form, every March 1st. The Tier I form requires minimum information on the general types and locations of hazardous chemicals present at the facility whereas the Tier II form requires more specific information. All states now require submittal of the Tier II form.
On July 13, 2012, EPA published revisions to the Tier I and Tier II forms in response to requests from state and local agencies for additional information. 77 Federal Register 41300 (July 13, 2012). The revisions add mandatory data elements and some optional data elements in the facility identification and contact information sections of the forms and also revise some existing data elements in the chemical reporting section of the Tier II form. Compliance will be required for reporting year 2013, with the Tier II form due on or before March 1, 2014 to the local planning and preparedness agencies with jurisdiction over the facility. Specifically, facilities will be required to report:
- Latitude and longitude of the facility;
- Identification numbers assigned under the Toxic Release Inventory and Risk Management Program;
- Whether the location where the hazardous chemicals are stored is manned or unmanned;
- The maximum number of occupants that may be present at a facility at any one time rather than the number of full time employees;
- Contact information of the individual(s) responsible for completing the Tier II inventory form;
- E-mail addresses of the owner or operator and emergency contact(s);
- Whether the facility is subject to EPCRA Section 302 and the Risk Management Program of Clean Air Act Section 112(r);
- Emergency coordinator contact information for facilities subject to EPCRA Section 302;
- Any additional state or local reporting requirements; and
- Description for the storage types and conditions rather than reporting codes.
The Tier II form will now also provide a place for voluntarily reporting hazardous chemicals below the reporting thresholds and will allow the option of providing a facility phone number, as well as parent company contact information. Also, separate data fields will be provided for reporting pure chemicals and mixtures in the chemical reporting section of the Tier II form. Additionally, the revised Tier II inventory form will also include the table of range codes and amounts for reporting maximum amount and average daily amount.
To view a complete PDF of the July/August 2012 issue of the Environmental Letter, click HERE.