Tier II Support Documentation and Compliance

• Compliance is shown through reporting… or even through NOT reporting.

• IHS understands that documentation is required to support information turned in on any report.

• HMMS users requested a detailed report to give them confidence in the data shown on the Federal Tier II worksheet.

• Tier II Support Documentation was created.

Quick Review

• What is the Tier II?• EPCRA• Requires all sites with hazardous materials

(anything with an MSDS) to report storage amounts over 10,000 lbs.

Tier II Review

Federal Tier II shows total storage by CAS Nr. Where do these numbers come from?

The report identifies each hazardous chemical reported on the Federal Tier II report by CAS number.

After the CAS number is identified, the NSNs and material name that contain the CAS number being reported are shown.

For each NSN and material name, the type of container in which the hazardous chemical is being stored is reported

The storage location of each container is reported.

For each of those containers, the amount of the specific chemical identified by CAS number in that container is reported.

The report shows the sum of the amount of the chemical (identified by CAS number) with the same NSN and material product number in the containers.

The sum of the amount of chemical identified by CAS number is reported. The amount shown in the Maximum Daily Total for CAS Nr field is the maximum amount of that chemical reached within the parameter date

Conclusion

• Tier II shows total storage by CAS Nr.• This support documentation report shows

where those totals and storage information comes from.

• Also provides NSN and material names to help users validate their data.

• Allows site to show that reporting is accurate, which keeps them in compliance.