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2015 EPCRA Tier 2 Hazardous Chemical Inventory Reports
WRITTEN BYKen Kirk, P.G.
EPCRA Tier 2 Hazardous Chemical Inventory Reports for the 2015 reporting year are required to be submitted between January 1st and March 1st 2016. Facilities subject to the OSHA Hazard Communication Standard which use, produce, and/or store a Hazardous Chemical or an “Extremely Hazardous Substance” (EHS); in excess of the “Threshold Quantity” (TQ) are required file EPCRA Tier II reports. The Kentucky Emergency Management (KYEM) recently released an updated version of the Commonwealth of Kentucky EPCRA “How to Comply” Packet. This document is available for download at the Kentucky Emergency Management (KYEM) web site: http://kyem.ky.gov/programs/Pages/SARATitleIII.aspx. This information provides step by step instructions required to be compliant with Kentucky and EPCRA regulations for the 2015 calendar year.
In Kentucky, the Tier2 Reports are required to be submitted online using the EPA’s Tier2 Submit program. The current Tier2 Submit software is available for download at http://www2.epa.gov/epcra/tier2-submit-software. After downloading the program, enter the requested information and save it to a file on your computer and upload the file to the KYEM Online Tier2 Submission page between January 1st and March 1st 2016.
A summary of the changes for the 2015 Tier 2 Report is provided below:
- Added a requirement that Title be filled out for Emergency Contact, Tier 2 Information Contact, and Fac. Emergency Coordinator contact types
- Replaced EHS checkbox with Yes/No radio buttons
- Added new “Replace Field Contents in Found Set” feature that will allow you to copy the contents of the current field to the same field on all the records in the found set
- Updated to latest NAICS list (used in ID drop-down list for Facilities), which also means that NAICS is now required to be a 6-digit code
- Added two new program checks to let you know when data is missing for cases where
(a) you have marked a facility as subject to the Risk Management Program, but you haven’t filled in an RMP ID value, and
(b) you have marked a facility as subject to section 302 of EPCRA, but you haven’t provided a Facility Emergency Coordinator contact for the facility
- Updated state-specific fields
- Upgraded to FileMaker 14
- Revised helps
- Made minor bug fixes and changes
The KYEM is currently developing a training course for the EPA’s Tier2Submit program to be available later this year. SMG can also assist facilities with your facility’s Tier 2 reporting and EPCRA compliance. If you would like our assistance please contact us.
A local company engaged in manufacturing imported a small amount of a chemical substance defined under TSCA. Faced with a potential EPA enforcement action with penalties assessed for noncompliance under TSCA of up to $32,500 per day per violation, the company called SMG for help.
SMG analyzed the company’s current TSCA procedures and assisted the company in developing a proactive, cost-effective compliance procedure. SMG also facilitated a training program to educate employees about TSCA.
SMG worked with the company to develop mechanisms that assured adherence with the policies that were being implemented for compliance. Procedures to promptly correct any potential violations and prevent future violations were also put into place.
SMG was able to show that the company complied with the relevant TSCA regulations and was improving their TSCA policies and procedures to assure that future issues were less likely to occur. The company was not subjected to the proposed penalties and now has mechanisms in place to maintain TSCA compliance.