EPA 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 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.
Does This Affect My Tier II Report?
The Tier II report, due March 1, 2019, will use the new EPCRA hazard categories. 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. Also, EPA has published a guidance document to help with the “cross-walk” between the old MSDS and new SDS hazard categories:
For more information on preparing and submitting your Tier II Report, please contact your EPS consultant.