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Tier II Reports for 2017 Due Soon

Tier II (or Tier 2) reports covering 2017 must be submitted by March 1, 2018. Tier II reporting is potentially applicable to recycling facilities and emerged from the Emergency Planning and Community Right-to-Know Act (EPCRA).

Tier II reporting is required if a facility is required by OSHA's Hazard Communication Standard to prepare or have a Safety Data Sheet for a hazardous chemical that is either an Extremely Hazardous Substance (EHS) or a non-EHS 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 its Threshold Planning Quantity (TPQ) or 500 lb, whichever is lower. Sulfur acid is an example of an EHS. For a non-EHS hazardous chemical, the threshold is 10,000 lb. Diesel fuel is an example of a non-EHS hazardous chemical.

If one of these thresholds is met or exceeded at your facility during a given calendar year (e.g., 2017), your facility must submit a Tier II report for that hazardous chemical by the following March 1 (e.g., by March 1, 2018). In most cases, Tier II reports are submitted to the state where your facility is located. You can find your state's Tier II portal here.

Last month, ISRI offered a webinar on Tier II reporting. You can find it (and any other webinar) in ISRI’s webinar archive. Information about other types of environmental reporting is available here.

If you have questions regarding Tier II reporting, please contact ISRI Chief Scientist/Director of Environmental Management David Wagger at (202) 662-8533.

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