• Tier II reporting is on or before the first of March every year.
• To prepare the reporting form, the owner or operator of the facility will need to gather the necessary data.

Basic reporting requirements

If required to comply with the hazardous chemical inventory reporting requirements, then:

• On or before the first of March every year the facility owner or operator must submit inventory information regarding any hazardous chemical present at the facility at any time during the previous calendar year in an amount equal to or in excess of its threshold level specified at 40 CFR 370.10.
• The facility owner or operator must submit Tier II information within 30 days of the receipt of a request from the State Emergency Response Commission (SERC), Tribal Emergency Response Commission (TERC), Local Emergency Planning Committee (LEPC), Tribal Emergency Planning Committee (TEPC), or the fire department having jurisdiction over your facility.

The completed form must be sent to each of the following organizations:

• Your SERC or TERC;
• Your LEPC or TERC; and
• The fire department with jurisdiction over the facility.

While the regulations at 40 CFR 370 Subpart C offer a minimal Tier I reporting form option, currently, all states require either a Tier II or state-equivalent form (hard copy or electronic) to be in compliance with the inventory reporting requirements. Therefore, the Tier I reporting option is not discussed here.

The Environmental Protection Agency (EPA) publishes the Tier II Inventory Form that provides a uniform format for reporting the Tier II information. EPA’s Tier II form is available on its website. A Tier II form, once filled in, contains specific information on a hazardous chemical present at the facility. Additional chemical information pages must be used as needed—one page for each hazardous chemical.

The Tier II form requires facilities to report specific information on the amounts and locations of hazardous chemicals. Separate fields are provided for reporting both pure chemicals and mixtures. For each entry, the facility owner or operator will check the box indicating if the chemical information is identical to the information submitted last year. Chemical descriptions, hazards, amounts, and locations must be provided even if the information is identical to that submitted last year.

States may impose fees for processing Tier II forms or even have their own forms that facilities must use to fulfill Emergency Planning and Community Right-to-Know Act (EPCRA) 312 requirements. Facility owners and operators should contact the SERC to determine a state’s requirements for inventory reporting formats, procedures, and state fees (if any) and to obtain inventory forms.

Gathering information

To prepare the reporting form, the owner or operator of the facility will need to gather the necessary data. The source of that data may be found anywhere, but the following entities may be able to help:

• The facility’s purchasing department may have information on chemical storage, including the maximum and average amounts present at the facility.
• Chemical suppliers should have sent the facility a safety data sheet (SDS) (or material safety data sheets (MSDS)) for the hazardous chemicals present at the facility.
• Forklift battery suppliers or vendors may be able to look up a battery model number and give the facility owner or operator the battery acid weight for each battery.
• The facility’s human resources department will have the number of employees, which will help in estimating the maximum number of occupants present at any one time.