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Tier II Reporting for Scrap Recyclers

Feb 19, 2021, 10:22 AM by EHS Update

Tier II (2) reporting is a requirement for all businesses who use hazardous chemicals or extremely hazardous substances (EHS) in their operations. Scrap recyclers are subject to this regulation, which requires reporting by March 1 each year. This is covered under the Emergency Planning and Community Right-to-Know Act (EPCRA) regulations, found in 40 CFR Part 370

The reporting threshold for an EHS is the lesser of 500 pounds or the EHS's Threshold Planning Quantity (TPQ); for a non-EHS hazardous chemical, the reporting threshold is 10,000 pounds (4536 kg). Even if neither threshold is met, you must report if so requested by your Local Emergency Planning Committee (LEPC), State Emergency Response Commission (SERC), or local fire department.  

If triggered by any of these circumstances for a given calendar year, you must report to the state (in most cases) by the following March 1.  It is important to note that exceeding these thresholds at your facility just once during a calendar year triggers reporting; these thresholds do not apply to an average level.

Examples of Substances That Trigger Reporting:

  • Diesel fuel at approximately 1,430 gallons (10,000 pounds);
  • Gasoline at approximately 1,590 gallons (10,000 pounds);
  • Sulfuric acid at 500 pounds (not its TPQ of 1,000 pounds); and
  • Ammonia at 500 pounds (its TPQ is also 500 pounds).

You can find your state’s Tier II portal here. Please reach out to the ISRI Safety team with any questions.

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