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Reminder: Tier II Reporting Deadline is March 1

Tier II (or Tier 2) reporting is potentially applicable to recycling facilities and is one type of reporting arising from the Emergency Planning and Community Right-to-Know Act.

Tier II reporting is required if a facility is required by OSHA's Hazard Communication Standard (HCS) to prepare or have a Safety Data Sheet for a hazardous chemical that is either an Extremely Hazardous Substance (EHS) (e.g., sulfuric acid and ammonia) or a non-EHS (e.g., diesel fuel) that is present on-site at or above the applicable threshold at any one time during a calendar year.

Generally, the threshold for an EHS is the lower of 500 lb. or the EHS's Threshold Planning Quantity (TPQ); for a non-EHS, the threshold is 10,000 lb. If triggered at a facility for a given calendar year (e.g., 2016), a facility's Tier II report for that year must be submitted by the following March 1 (e.g., in 2017) to the state (in most cases). You can find your state's Tier II portal here. Information about Tier II reporting and other types of reporting can be found here.

If you have questions regarding Tier II reporting, please contact David Wagger, chief scientist / director of environmental management for ISRI, at (202) 662-8533.

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