Tier II Reporting Marches Ever Closer

With the annual deadline of March 1st looming ever nearer, many businesses and industrial facilities must once again go through the process of submitting their Tier II Reporting to their respective states.

What is Tier II?

Tier II Chemical Reporting creates a database of substances that could be considered potentially hazardous to public health. In the event of an emergency at or around a facility, local emergency response can be tailored to the, “quantity, location, and potential hazards” (EPA) of chemicals present. The requirements are mandated under the Emergency Planning and Community Right-to-Know Act (EPCRA) and administered, in Texas, through the Texas Commission on Environmental Quality (TCEQ).

Who does it apply to?

Tier II Reporting is required by facilities including but not limited to; oil and petrochemical (extraction, refining, and storage), metal manufacturing. Generally, a facility needs to reach the threshold of 10,000 lbs. per chemical in order be regulated under Tier II.

There are some exceptions, for example retail fuel service stations have a much higher threshold of 75,000 gallons of gasoline and 100,000 gallons of diesel. Many specific guidelines within the regulations exist and we are here to help decipher them.

A detailed inventory of all chemicals present will be conducted.

A detailed inventory of all chemicals present will be conducted.

Why is it important?

In the event of an emergency, valuable time can be saved by knowing what is stored at a given location. During Hurricane Harvey, there was a massive fire at a chemical plant in Crosby, northwest of Houston. According to their Safety Data Sheets over 350,000lbs of Organic Peroxides were there to combust. 200 nearby residents were forced to evacuate for a week with 21 needing treatment primarily due to inhalation of smoke. Local hospitals and fire departments were able to be informed about the challenges presented by the incident because they had proper documentation.

How do I report?

 The TCEQ provides an online program through STEERS where a facility can be registered and the associated fees can be paid. Registration requires a detailed inventory of chemical: quantities, locations, health risks, and other pertinent information to be within compliance.

Latitudes is a Texas consulting firm who can help you obtain your regulatory authorizations.  The consultants here at Latitudes Environmental are experts with the system and ready to assist with the process. We have experience with permitting various types of facilities for their air, water and waste compliance needs.