Tier II Preparation Checklist
Tier II reporting is only available for SDS Management and SDS/Chemical Management accounts.
You can use your Chemical Management account to generate a Tier II report provided you’ve completed several steps. These steps include:
- Create locations in your account
- Audit your SDSs and Containers
- Add safety data sheets for your products to your eBinder
- Assign safety data sheets in your eBinder to locations
- Index ingredients for your products
- Index GHS Classifications and Precautionary Statements for your products
- Index Physical Properties for your products
- Create Containers for your products
- Review your data
- Generate the Tier II report
1. Create locations in your account
Because Tier II reports need to be filed for a specific physical address, that location needs to be created in your account. See Creating Locations for information on creating locations in your account.
2. Audit your SDSs and Containers
Make sure the information in your Chemical Management account mirrors that of your physical inventory. Walk through your facility and update your eBinder and container information accordingly. Add any missing safety data sheets or containers, and update any incorrect document versions or container quantities and statuses.
3. Add safety data sheets for your products to your eBinder
In order to track quantities of products and ingredients as well as index other information required on the Tier II form, you first need to have the safety data sheet for that product in your eBinder. See Adding safety data sheets to your eBinder for more information.
4. Assign safety data sheets in your eBinder to locations
Tracking quantities of products and ingredients requires creating containers and containers need to be created a locations. Therefore, your safety data sheets need to be assigned to locations first. See Assigning Products to Locations for more information.
5. Index ingredients for your products
Tier II reports require you to report on specific chemicals. Therefore, you need to index the ingredients for your products before the Chemical Management system can determine if those chemicals are on the EPCRA Section 302 Extremely Hazardous Substances (EHS) list. See Ingredient Indexing for information about how to index ingredients in your account.
6. Index GHS Classifications and Precautionary Statements for your products
In 2017 the EPA changed the Tier II form to include physical and health hazards tied to the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). These fields correspond to the GHS Classifications and Precautionary Statements indexing modules in your account. Therefore, to ensure this information appears on your Tier II form you need to index these modules for your Tier II reportable products. See GHS Classifications Indexing and Precautionary Statements Indexing for more information.
7. Index Physical Properties for your products
In order for the Chemical Management system to calculate the weight in pounds for your products and ingredients you must index the Physical Properties indexing module. While there are many fields in the Physical Properties module, the following are required for Tier II reporting:
- Physical State
- Vapor Density
- Specific Gravity or Relative Density
For more information, see Physical Properties Indexing.
8. Create Containers for your products
The Chemical Management system uses the size of the containers you’ve created in your account for your products to calculate whether or not any of your Tier II reportable chemicals are above the Section 302 EHS Threshold Planning Quantity (TPQ). Therefore, in order to accurately calculate amounts, you must create containers for your products. See Creating and Managing Containers for more information.
9. Review your data
Once you’ve completed all the steps above, you can review the information and determine if any of your product or ingredient quantities meet or exceed the EPA’s thresholds by generating the Tier II Threshold Report.
To verify that you’ve captured and completed all of your required Tier II reporting information, generate the SARA 311/312 Report. VelocityEHS recommends you review the information on this report for accuracy and use it to address any erroneous information in advance of generating your Tier II report.
The Environmental Protection Agency (EPA) says that a facility has to comply with EPCRA Section 312, known as annual Tier II Reporting, if it is required by OSHA to maintain safety data sheets for hazardous chemicals stored or used in the workplace, and if it has those chemicals in quantities that meet or exceed the following thresholds:
- For Extremely Hazardous Substances (EHS)(40 CFR part 355 Appendix A and Appendix B), either 500 pounds or the Threshold Planning Quantity (TPQ), whichever is lower
- For gasoline (all grades combined) at a retail gas station, the threshold level is 75,000 gallons*
- For diesel fuel (all grades combined) at a retail gas station, the threshold level is 100,000 gallons*
- For all other hazardous chemicals: 10,000 pounds
* If the tank(s) was stored entirely underground and the tank(s) was in compliance at all times during the preceding calendar year with all applicable UST requirements at 40 CFR part 280 or requirements of the State UST program approved by the Agency under 40 CFR part 281.
Additionally, you can use the container reconciliation feature to ensure that all the containers in your account are up-to-date.
10. Generate the Tier II report
After you’ve completed all of the steps above you’re ready to generate your Tier II report. For details on generating either a printable Tier II report or a .zip file that can be used with Tier2Submit or E-Plan, see Creating the Tier II Emergency and Chemical Inventory Form.
