the dry presentation of the conference

“Form R and Tier II”

by Susan Murphy     

The Basics of Tier II Hazardous Chemical Reporting, Community Right-to-Know

"Tier II” is the reporting form nickname

The purpose is to provide the public with info on hazardous chemicals in their community There are 16 fertilizer production sites in Texas like the one

that exploded in West, but authorities aren't clear how many of those might be built near schools or other residential centers,…

40CFR370

Hazardous Chemical Reporting, Community Right-to-KnowAnything on site requiring

an MSDS is subject to Tier II reporting

Standard threshold of 10,000 lbs maximum quantity on hand, but threshold is smaller for more hazardous materials

40CFR370The Basics of Tier II

Include railcars of chemicals, and biofuels that we are shipping off site (animal fats,oils), wastewater treatment chemicals, CO2

The certifying official needs to know what the codes mean

40CFR370The Basics of Tier II

Some states collect fees on Tier II chemicals to fund the LEPCs

40CFR370The Basics of Tier II

EPA inspectors are most familiar with Tier II

40CFR370The Basics of Tier II

Easy to audit

• Keep supporting documentation for chemicals you did and did not put on Tier II for ECAP audits

Keep proof of delivery• Scan Tier II and delivery proof into WEBEMS

The Basics of Form RToxic Chemical Release Reporting (TRI), Community Right-to-Know

“Form R” is the reporting form nickname

Also known as TRI or SARA 313 or Title III

Purpose is to inform the public of releases of toxic chemicals, and to aid in regulation development

40CFR 372

The Basics of Form R

TRI data is easily accessed in ECHO

40CFR 372

FRS_ID Facility_Name Address City State Program IDTRI Chemical Releases (lbs)

GHG Releases (metric tons

CO2)

110000414347FARMLAND FOODS INC

800 INDUSTRIAL DRIVE DENISON IA GGR:1005415   68,327

         TRI:51442FRMLNINDUS 104,032  

110011093173FARMLAND FOODS INC

22123 HIGHWAY 5 MILAN MO

TRI:63556PRMMSRURAL 311,297  

110000596855FARMLAND FOODS INC HWY. 103 S. CRETE NE

TRI:68333FRMLNPOBOX 1,816,072  

          GGR:1005520   69,102

The Basics of Form RToxic Chemical Release Reporting, Community Right-to-Know

“There are three categories: manufacture, process, or otherwise use, each with its own reporting threshold

The state and EPA collect the information

EPA’s Central Data Exchange (CDX) online reporting tool is available

40CFR 372

It is simple to look up a facility at EPA’s ENVIROFACTS

Test Your Knowledge

Form R or Tier II?

Due July 1 every year

There is a chemical list

Includes rock salt for deicing

grounds

Fire Dept gets a copy

Due March 1 every year

Hydrogen Sulfide was added for

2012

Food ingredients are exempt

Authorizes fire dept. inspections

Report how much you send to your city wastewater

plant

Can be reported electronically using

EPA’s CDX

Test Your Knowledge

Form R or Tier II?

Has a mandatory Pollution Prevention

section

Refrigeration system capacity is

needed

The database went down this year on

the due date

Requires updating reported info within 3 months of adding

a chemical over threshold

Data can be found in EPA’s ECHO

database

Until next year…