Common Tier II Reporting Problems (and How We Fix Them!)

1. Bad Data Is the Number One Tier II Reporting Mistake

Tier II reporting is only as good as your data. If inventories are out of date, SDSs do not match what is on the floor, or a “temporary” tote was never accounted for, your report will be wrong. We have found 10,000-gallon diesel tanks missing from reports, product containers misidentified entirely, and “phantom” chemicals that were removed years ago but still show as actively on-site.

Tier II is based on what is physically present on site. Not what you bought, not what you used, not what you think you have. Wrong data creates compliance exposure, and it also creates real risk for emergency responders who rely on your report to plan their response.

How we fix it: RMA starts with a full inventory reconciliation. We go aisle by aisle and container by container, match SDSs to what is on hand, and check reportable thresholds even when trade names or vague hazard language make it tricky. When we are done, your report reflects reality, and you can defend it.

2. No Clear Owner for Tier II Reporting

Who is actually in charge of Tier II reporting at your facility? All too often, we hear "well, it's complicated" when we asl that question. If someone isn't directly responsible for overseeing Tier II reporting (someone who actually understands it) - nobody is.

Purchasing manages materials, EHS manages SDSs, operations runs the floor, and accounting watches the spend. Then February arrives and nobody is sure who is supposed to file. Sometimes last year’s report gets copied forward by someone who has never set foot in the facility in a scramble to meet the March 1st deadline. That is how mistakes multiply.

How we fix it: We define roles, deadlines, and handoffs. We can guide your team, or we can take the reins and file for you. Either way, you get structure and repeatability year after year.

3. Confusion About Thresholds, Quantities, and Reporting Level

What exactly are we reporting? Which materials are Extremely Hazardous Substances? What counts as the maximum amount on site? Should we file by site or company? State and local quirks add even more gray area to an already confusing regulation.

So, what happens? We see both sides of the coin: underreporting from missed triggers, and overreporting from playing it safe. Some companies risk getting in trouble for failing to correctly file their reports. Others spend way too much time and energy reporting things they don't need to. Lose-lose.

How we fix it: We verify substances against federal and state lists, confirm thresholds, and right-size your filing level. One site or fifty, we make the rules clear and the data clean.

4. Portals, Passwords, and Technology Nightmares

Here's one of the biggest mix-ups: exactly how you prepare and submit your Tier II reports is going to depend on your state. And there is a lot of confusing and conflicting information on the internet about how to prepare your report and who to submit it to. Especially confusing if you're in charge of reporting for multiple locations across state lines!

And they aren't all made equally. Some states have smooth online systems. Others feel like dial-up (if you were born after 2000, you can ignore this one - old people stuff). Some states are even still using mail-in paper submittals like it's the 1980s. And even when a state has a decent online system, there are always headaches. Logins expire, uploads choke, and portals crash near the deadline (that last one is very, very common, by the way). If you miss the date, the system problems are still your problems.

How we fix it: We know the major portals and Tier2 Submit workflows. We file early, retain proof of submission, and document a step-by-step process so next year is a breeze instead of a scramble.

5. Remember: Tier II Reporting Is Public-Facing

Your data could be reviewed by watchdog groups, journalists, or even concerned residents. And if your report looks sloppy, incomplete, or just copied from last year, it can draw the wrong kind of attention fast. Mistakes that your state reviewer might overlook could still end up flagged online by someone who knows what they’re looking for.

And beyond reputation, there’s a real safety risk. If a fire, spill, or release happens and your report doesn’t reflect what’s actually on-site, first responders could walk into danger blind. Inaccurate filings don’t just lead to fines, they can lead to liability, investigations, and serious harm. These reports exist for one reason: to keep people safe. When they’re wrong, that purpose is lost. Don't let your Tier II report become a headline in the local paper.

How we fix it: We make sure your Tier II filings are accurate, defensible, and crystal clear. We verify your data, catch inconsistencies, and, for operations with community visibility, help craft context and communication that build trust. These reports are a reflection of your company’s credibility. Let’s make sure they show the truth.

The Fix That Keeps You Out of Trouble Next Year

Tier II does not have to be miserable. Start early, verify what is on the floor, assign ownership, and build a repeatable workflow. With a reliable system, Tier II becomes routine and defensible.

RMA provides audits, inventory reconciliation, multi-site coordination, staff training, and done-for-you filing. If you want peace of mind, reach out and we'll map the fastest path to a clean, on-time submission. Here's the summary:

Final Thoughts and Next Steps

Tier II reporting isn’t just another regulatory box to check. It’s about protecting your people, your community, and your operation from unnecessary risk. The truth is, Tier II mistakes are common... but they’re also completely preventable when you have a clear system and experienced guidance on your side.

At RMA, we’ve built a proven Tier II reporting process that takes the guesswork (and the stress) out of compliance. We start by reviewing your facility’s chemical inventory, cross-checking Safety Data Sheets (SDS), and confirming reportable thresholds. From there, we prepare, review, and submit your Tier II report to the appropriate state and local agencies - accurately, defensibly, and on time.

Whether you just want a second set of eyes to double-check your work or you’d rather hand the whole thing off and let us manage it from start to finish, we’ve got you covered. Our team will make sure your Tier II report is right the first time so you can move forward with confidence knowing your operation and community are protected.

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