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Ready for EPCRA (Tier II) and RCRA (Hazardous Waste) Reporting?

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November 13, 2019Regulatory Reporting TeamBlog

The March 1 deadline is quickly approaching for annual EPCRA Tier II and RCRA Hazardous Waste reporting. Now is the time to review requirements and obligations to prepare for a successful submission.

EPCRA Section 312 Tier II Reporting

The EPCRA Tier II report is specifically for hazardous materials, not waste. Reporting is done at the state and local level and provides the U.S. Environmental Protection Agency (EPA) with data on the type, quantity and location of hazardous chemicals.

EPCRA Reporting Requirements

You are required to submit an EPCRA Tier II report if your facility must:

  • Submit SDSs or list hazardous chemicals under Section 311 of the Occupational Safety and Health Administration (OSHA) regulations for hazardous chemicals stored or used in the workplace
  • Submit an annual inventory report for the same chemicals

EPCRA Reporting Obligations

While Tier II is a federal obligation reporting is done at the state and local level through the EPA’s Tier2 Submit software that generates a report. The reports are submitted to the State Emergency Response Commission (SERC), Local Emergency Planning Committee) LEPC and local fire department.

You must report if any of the following quantities (equal to or greater than) were present at your facility during the calendar year:

  • 500 pounds of extremely hazardous substances (EHS) or threshold planning quantities (TPQ)
  • 75,000 gallons of gasoline
  • 100,000 gallons of diesel
  • 10,000 pounds of other hazardous material or chemicals

RCRA Hazardous Waste Reporting

RCRA establishes the hazardous waste reporting guidelines at the federal level while granting individual states the opportunity to create more stringent guidelines in lieu of federal requirements so they can implement their own waste program.

RCRA Reporting Requirements

This is a biennial report and it is only required for Large Quantity Generators. Any facility that is generating within the Small Quantity Generator limits is exempt along with Very Small Quantity Generators.

RCRA Reporting Obligations

You must follow the requirements specific to your state and if your state does not have its own hazardous waste program, you are required to follow the criteria outlined in Subtitle C of RCRA. This criterion regulates hazardous waste generators, transports and facilities that handle treatment, storage and disposal. This also includes permitting requirements, enforcement and corrective action or cleanup.

Additional Resources

To further prepare for your EPCRA (Tier II) and RCRA (Hazardous Waste) reporting check out these resources:

Our regulatory reporting experts are available to assist with your EPCRA and RCRA reporting. Fill out this form and a representative will contact you to streamline a solution that best fits your needs.