EPCRA Section 312 includes a two tier approach. Tier I requires information (such as maximum amount of hazardous chemicals at the facility during the preceding year, an estimate of the average daily amount of hazardous chemicals at the facility, and the general location) be aggregated and reported by hazard categories. Tier II not only requires the information mentioned above, but also requests information on specific location and storage.
Aboveground Product Vessels
The primary difference between EPCRA Tier I and Tier II reporting lies in the level of detail provided about hazardous chemicals. While Tier I provides a general summary of hazards, Tier II requires specific information for each individual chemical.
Key Differences
| Feature | Tier I Reporting (General) | Tier II Reporting (Specific) |
|---|---|---|
| Data Detail | Information is aggregated and reported by hazard category rather than specific chemical. | Detailed information for each individual hazardous chemical. |
| Location Info | Provides the general location of chemicals within broad categories. | Requires specific storage locations and manner of storage for each chemical. |
| Regulatory Status | Minimum federal requirement under Section 312 of EPCRA. | Required upon request by local or state agencies; however, most states now mandate Tier II. |
| Public Access | Citizens can obtain general information during normal working hours. | Citizens must submit a written request for specific facility data. |
Reporting Requirements
Facilities must submit these forms if they store hazardous chemicals above the following thresholds:
- Hazardous Chemicals: 10,000 pounds or more.
- Extremely Hazardous Substances (EHS): 500 pounds or the Threshold Planning Quantity (TPQ), whichever is lower.
- Deadline: Reports must be submitted annually by March 1 to the State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC), and the local fire department.
Most facilities choose or are required to submit the Tier II form because it automatically satisfies the minimum requirements of Tier I while providing the granular data needed by emergency responders.
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