Because the USEPA has adopted GHS, reporting requirements under EPCRA have expanded. GHS added a number of hazard categories and thus Tier 2 reporting requirements have also been added. The new Tier 2 form now has 13 physical hazard choices and 11 health hazard choices. The following table lists the new categories:
New Hazard Categories for Tier 2 Reporting
MDEQ Requesting Companies to Submit their Tier II Reports Early: The MDEQ is asking Michigan facilities to start updating their Tier 2 reports now [in 2017] to avoid the rush in January and February of next year. The MDEQ Tier ll Manager program is updated and ready to go.
USEPA has not yet released the updated Tier 2 Submit software for CY 2017. We’ll keep you posted on this one.
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 one of our professionals at SRM. We can get you through this year of reporting and get you up to speed on the new reporting requirements so you will be ready for 2018. Give us a call now!
USEPA link MIOSHA Link