Because the USEPA has adopted GHS, the reporting requirements under EPCRA have expanded. The Tier 2 reporting requirements now have 24 physical and health hazard categories. The new Tier 2 form now has 13 physical hazard choices and 11 health hazard choices. The following table lists the new categories:
The MDEQ is asking Michigan facilities to start updating their Tier 2 reports now to avoid the rush in January and February. The MDEQ Tier ll Manager software system is updated and ready to go!
USEPA has released the updated Tier 2 Submit software for CY 2017 for those companies with facilities in other states.
Helpful Hint in preparing 2018 Tier 2 Reports: Be sure to obtain updated SDSs. They will be incredibly helpful in selecting the hazard category for the chemicals you have on site. If you need assistance updating your Tier 2 report for 2017, contact our professionals at SRM.
For more information, check out the following links for the MDEQ and USEPA web sites
By now you should be knee deep in assembling information reviewing data and getting ready to prepare and submit your Q1 reports.
OSHA 300A Logs – Your OSHA Log Posting is due February 1st. Make sure you have re-reviewed some 2016 incidents with your incident investigation team to ensure you have all the information you need and that it is still current. Sometimes reporting information changes weeks and even months after an incident so you want to be sure days away, transfer and other information is still correct.
Hazardous Waste Biennial Report – Review your waste shipping records to verify you have all the original signed manifests, LDR documents and waste characterization files for all wastes generated during 2016. Do a quick generator status check to determine whether or not your generator status has changed.
Tier 2 Reports – Has your company started any new processes this past year or started storing new chemicals on site? If so, determine the quantities you now store and how the materials are managed. This is a good time to update your chemical inventory.
Air Permit Reports – Depending on your emission units and permit terms and conditions, you may have monthly, quarterly, semi-annual and annual reports to submit. It is a good idea to check in with the staff responsible for collecting the data to ensure it will be available when needed and it is accurate.
Online Reporting Access – Just like the fire department wants you to check the batteries in the smoke detectors in your home, the new year is a good time to check your online access user names and passwords to make sure they are current and still work. Some agencies require you to change your password annually. The new year is a good time to make sure that everyone involved in the reporting process still knows their login information. Getting these items resolved now will help avoid headaches as you approach reporting deadlines.
If you have questions, give us a call and we will be happy to help.