|What the regs require |
|The Environmental Protection Agency’s (EPA) Emergency Planning and Community Right-to-Know Act (EPCRA) SARA Title III, Section 312 requires any facility that uses, stores, or processes a chemical requiring a Material Safety Data Sheet (MSDS) held above certain quantities to file a Tier II report. The Tier II reports are due on or before March 1st of each year. |
EPCRA Section 325 allows civil and administrative penalties ranging up to $10,000-$75,000 per violation or per day per violation when facilities fail to comply with the reporting requirements.
|Do I need to file Tier II's? |
|The next few questions will help you answer the above. If you can answer “No” to any of the following questions then you may be in the clear: |
Question #1: Do you do any one of the following; manufacture, use, store or process chemicals? (The simplified definition for “chemical”, pertaining to these regulations, is a product that you are required to maintain a MSDS. They include solids, liquids and gases.)
Question #2: Do you have chemicals contained within these products that contain any of the extremely hazardous chemical (EHS) list?
Question #3: Do any of these “Chemicals”, either by themselves or aggregated (based on your maximum amounts on any given day), meet or exceed the EHS Threshold Planning Quantities (TPQ) or 500 lbs.? (The only way that we can help you with this one is to screen for them.)
Note: Even if you answered “No” to either question 2 or 3 you still may have a requirement if you have any chemical that exceeds 10,000 lbs on hand any given day at you facility.
|Our View: E&SSG has provided chemical screening services that have helped our clients cut through the regulatory red tape of regulated chemicals since 1993.
E&SSG has developed many systems to effectively track your chemical inventory and provide you "Peace of Mind" about your chemical requirements.
|What We Offer |
|Tier II Screening Service |
|This service is designed to virtually eliminate the amount of time you would spend studying the SARA Title III regulations as well as searching, cross-referencing and indexing your chemical inventory against the SARA Title III EHS list. |
This simple and painless service provides you with the information you need to determine if you are required to file a Tier II.
|The entire process can be completed in as little as a few days.* |
|Initially you simply provide to us copies of your Material Safety Data Sheets (MSDS) that represents your current chemical product inventory. |
|Our staff of trained professionals enter key information from your MSDS into our system. |
|We send you back either an E-mail or hardcopy** form requesting your product inventory information on the just the products, present at your facility, that contain these regulated chemicals. This information includes your quantities, container types, areas stored and areas used. |
|Logical ||After the information is received back from you and entered into your file, E&SSG's proprietary CIA software matches your inventory against the hundreds of chemicals listed on the EHS list. |
|The reports of the findings and/or compliance instructions are then delivered back to you in PDF format. |
|The reports that you receive will show you weather or not you are required to file a Tier II and why. This includes the following 3 reports complete with detailed information showing your: |
• Basic Total Chemical Inventory**
• Extremely Hazardous Substances (EHS) Chemicals
• 10,000 lb. Chemicals
|Ongoing ||This service is a renewable annual (12 month) service that allows you to provide us your new or revised MSDSs as your chemical inventory changes. This allows us to monitor the changes in your inventory along with any changes or modifications to the EHS list and notify you if your status changes. |
|If required by the report findings pertaining to Tier II. E&SSG will prepare and file your State and Local reports as follows: |
1) Tier II Reporting – Just an additional $50/facility filing fee with this service.
|Coming Soon ||E&SSG will provide you secure access to your chemical inventory online via E&SSG's Compliance Watch Dog. This will allow CIA users to view the above up-to-date reports, and much more, as their inventory changes. |
* Results are subject to demand and response time from the client.
**This is a basic Total Chemical Inventory report that will list just the MSDS Number, Product Name and Manufacturer, and Maximum Pounds (if given).