EPCRA Tier II Reporting

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With the new year quickly approaching, it's important to note that the USEPA has made a change to EPCRA (Emergency Planning and Community Right-To-Know Act), Sections 311 and 312 (Tier II) reporting. They are changing how reporting is done as of January 1, 2018. Since OSHA adopted the Global Harmonization of Systems (GHS) protocol in March 2012, the EPA has updated their hazardous chemical inventory reporting requirements to marry up with the new OSHA GHS standard. The reporting format is now modified to include the 13 physical hazard and the 11 health hazard categories that originate from your Safety Data Sheets (SDSs) of the reportable chemicals kept onsite.

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As you may have heard, the acronym MSDS is no longer. SDS has taken its place and so the Tier II reports due March 1, 2018 must now mimic those SDSs. Online reporting has helped speed up reporting time immensely, but recently, the state regulatory agencies across the United States have modified their software and now allow you to populate those categories. So, please add some time into your schedule this upcoming reporting season for reviewing your reportable chemicals and populating those categories in your reports. Otherwise, you’ll get that dreaded call from the agency asking you to modify your reports. You know how much fun that is!

If you haven’t gotten all of your SDSs up-to-date, NOW IS THE TIME to get them updated so that not only is your Hazard Communication (HazCom) program compliant, but you’ll also be compliant with your Tier II reporting. If you have questions, give us a call at (800) 508-8034.

Blog Author

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Greg Towler, Senior Project Manager, EHS Compliance Services, KERAMIDA Inc.

Contact Greg at gtowler@keramida.com.