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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…