Tier 2 Hazardous Chemical Inventory Reporting

Under EPA’s SARA Title III, Community Right-to-Know Act, owners or operators of facilities that have hazardous chemicals on hand in quantities equal to or greater than set threshold levels must submit a Tier 2 report form by March 1st of each year. This Tier 2 report is also called the Emergency and Hazardous Chemical Inventory Form.

The completed forms are to be submitted to the local fire department and to the County and State Emergency Planning Agencies. Specifically for Illinois, the Illinois Emergency Management Agency (IEMA) requires that the filing of the report, with all attachments, is through the state’s IEMA Tier II Manager website. Paper copies are required to be sent to the local fire departments and the Local Emergency Planning Committees (LEPCs).

IEMA requires that all reported Tier 2 chemicals have a current electronic SDS included on the Tier 2 web site. The format must be in an acceptable, so that emergency responders have quick access.

All submitted Tier 2 report forms continue to take on increased importance as many local fire departments are updating their electronic records to document the amount of extremely hazardous substances stored in their geographic response area. Additionally, county emergency response agencies, through coordinated efforts with local fire departments, are upgrading sophisticated emergency response plans to handle chemical spills and releases in their areas.

Chemicals commonly used in manufacturing, such as ammonia, heavy metals, nitrates, and even sulfuric acid in fork lift batteries are frequently overlooked by facilities, but are still very much subject to reporting. Many companies have been fined by the United States Environmental Protection Agency (U.S. EPA) for failing to report these frequently overlooked chemicals.

City of Chicago Facilities

In addition, the City of Chicago requires a more detailed emergency preparedness diagram. Chicago’s new ordinance also has recordkeeping requirements and establishes that the City can inspect and enforce Tier 2 reporting.

Special Reporting Under EPCRA Section 302

If a facility brings an Extremely Hazardous Substance (EHS) on-site in a quantity that exceeds its Threshold Planning Quantity (TPQ), it must submit a Section 302 Notification within 60 days. This notice can also be done on the Tier II Manager website with paper copies sent to local agencies.

The facility must also provide notice to the Local Emergency Planning Committee of any changes that may be relevant to emergency planning, within 30 days of the change. This includes: moving the substance to a different location, the substance is no longer present, or the facility is no longer in operation.