March 1 is the deadline for covered facilities to file Tier II Hazardous Chemical Inventory Reports. Under Section 312 of the Emergency Planning and Community Right-to-Know Act (EPCRA), this requirement applies to your facility if at any time you have more than threshold amounts of hazardous substances on your site. 
The threshold quantities are the lower of either 500 pounds or the threshold planning quantity for extremely hazardous substances, and 10,000 pounds for other hazardous substances (subject to certain exemptions that apply for hazardous wastes, tobacco, wood products, manufactured “articles,” food, drugs, cosmetics, alcohol and agricultural products, and higher thresholds for fuel storage at retail gas stations).
The list of extremely hazardous substances and their threshold planning quantities can be found at www.epa.gov/emergencies/docs/chem/title3_Oct_2006.pdf. Other “hazardous substances” include materials that are hazardous as defined in the OSHA Hazard Communication Standard (29 CFR 1910.1200); generally, any material for which a Material Safety Data Sheet (MSDS) is required.
Tier Two reports should be provided to the State Emergency Response Commission, Local Emergency Planning Council and local fire department.
EPA offers a software program, “Tier2 Submit,” to facilitate preparation and submittal of Tier Two reports. Note, however, that many States may require additional information or alternative reporting formats, as well as payments of associated fees. Visit www.epa.gov/emergencies/content/epcra/tier2.htm for further information, including access to the Tier2 Submit software and links to State requirements, or contact us for assistance with preparation of your Tier Two reports.
