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EPA’s Revisions to EPCRA 312 Tier II Reporting

EPA has issued revisions to 40 CFR Part 370 that affect Tier I and Tier II reporting under Sections 311 and 312 of the Emergency Planning and Community Right to Know Act (EPCRA). The revisions affect the Tier II report due March 1, 2018 for the 2017 reporting year. The changes are intended to align EPCRA with the revised OSHA Hazard Communication Standard (HCS) which adopted the Globally Harmonized System of Classification and Labeling of Chemicals referred to as “GHS.”

Tier II Reports – Here’s What Changed:

EPA has revised the hazard categories on the Tier II reports. In place of the current five hazard categories (fire, sudden release of pressure, reactive, immediate (acute) health hazard, delayed (chronic) health hazard), EPA is adopting the hazards used in the HCS, which are listed below:

Physical Hazard

  • Flammable (gases, aerosols, liquids, or solids)
  • Gas under pressure
  • Explosive
  • Self-heating
  • Pyrophoric (liquid or solid)
  • Oxidizer (liquid, solid or gas)
  • Organic
  • Peroxide
  • Self-reactive
  • Pyrophoric gas
  • Corrosive to metal
  • In contact with water emits flammable gas
  • Combustible Dust
  • Hazard Not Otherwise Classified (HNOC)

Health Hazard

  • Carcinogenicity
  • Acute toxicity (any route of exposure)
  • Reproductive toxicity
  • Skin Corrosion or Irritation
  • Respiratory or skin sensitization
  • Serious eye damage or eye irritation
  • Specific target organic toxicity (single or repeated exposure)
  • Aspiration hazard
  • Germ cell mutagenicity
  • Simple asphyxiant
  • Hazard Not Otherwise Classified (HNOC)

How Does This Affect My 2017 Tier II Report?

The Tier II report, due March 1, 2018, will use the new EPCRA hazard categories above. So, between now and February 2018, make sure you have current Safety Data Sheets (SDS) for previously-reported and new chemicals and familiarize yourself with the hazard classifications listed in Section 2 of the SDS. Previously-reported chemicals will likely need to be reevaluated for the new hazard categories based on updated GHS-compliant SDS.

The new categories are expected to be available in the reporting year 2017 versions of the reporting software (Tier2 Submit and E-Plan). Some states still require forms. Reporting information for each state can be found at:

https://www.epa.gov/epcra/state-tier-ii-reporting-requirements-and-procedures

Also, the hard-copy form and instructions are available at:

https://www.epa.gov/epcra/tier-ii-forms-and-instructions

For more information on preparing and submitting your Tier II Report, please contact your EPS consultant.

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