There should never be anything left to chance regarding the usage and care of hazardous chemicals in your business. That is why EPA requires an annual report your chemical inventory. Below is a list to make performing this important task as less hazardous as possible.
Hazardous Chemical Inventory Report Due to EPA on March 1
Companies that need to report are those with a hazardous chemical that falls under the EPA hazard communication rule. So, are you presently harboring an EPA-hazardous chemical? While there’s no official listing, EPA defines a hazardous chemical as “one that poses a physical hazard or health hazard.” They provide a 20-count criteria for determining if something IS a hazard along with hazard communication resources on their website.
Specific materials that require reporting are any on-site chemicals at or above their threshold quantities—10,000 pounds or more present at one time—during the previous year. For extremely hazardous substances (EHS), the reporting threshold is the lower of either 500 pounds or the threshold planning quantity. (Gasoline and diesel fuels fall under separate reporting thresholds.) To determine whether you have met the reporting threshold for EHS, you need to aggregate the amount of the EHS in mixtures with other EHS quantities. (The threshold for gasoline and diesel fuel applies to the aggregate of all blends). Responding to local authorities’ request for a chemical inventory report is absolute: even if you have not exceeded any thresholds, they can request and receive information on any hazardous chemical in any quantity.
Your annual report must also be submitted to your emergency planning committees on the local and state level, as well as to your local fire department. The EPA maintains a searchable online database of LEPCs (local level) and a comprehensive list of SERCs (state level).
Forms To Send
As may be expected, filing the proper forms PROPERLY is critical to staying compliant for housing hazardous chemicals. As a rule, you may submit either a Tier I form (linked) for your ENTIRE inventory, or Tier II forms (linked) for EACH chemical.
Tier 1 Forms
A Tier I form must include general information about all the chemicals at your facility, including the maximum amounts present, the potential physical and health hazards posed by each, average daily amounts present, their general locations at the facility, number of days on site, and other information as deemed necessary.
Tier II Forms
A Tier II report must include specific information per each, including:
- CAS number
- Chemical /common name
- Whether pure or a mixture
- Physical state
- EHS or non-EHS
- Hazard category
Be prepared to provide both forms if necessary.
Submit your report electronically for Tier II forms only if accepted by your state. The EPA provides software for this as well as directions on their Tier II Chemical Inventory Reports page.