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Written By: Doug Ruhlin | Mar 4, 2015
Time to Read 6 Minutes
Tier II Community Right to Know Reporting is just about done, which means (at least for us here in the office) we're starting to turn our sights onto Toxic Release Inventory Reporting. However, we're still getting folks letting us know "we'll get Community Right to Know done for the July 1st deadline" or "we just finished submitting our toxic release inventory information."
Unfortunately, both of those statements (which are real and from people who aren't our clients, just good friends...) are both WRONG!
The amount of confusion over these two reporting requirements is insane, but we get it. Both are confusing, both are poorly enforced, and the regulatory agencies in charge of them give you almost no guidance on them. No wonder people perpetually get it wrong!
Federal EPCRA regulations require two very different types of annual reporting about the storage, manufacture, processing or use of hazardous and toxic materials at a wide range of facilities in the U.S. It’s critical to understand that they both are not the same and have very different criteria and requirements. If you don’t understand this, you could potentially risk significant penalties and other enforcement possibilities.
The answer to the question is so simple, but I’m not going to give it you right away (although I am sure you can guess where this is going...)
Here's a breakdown of both reporting requirements and some information about them:
So what’s the answer, is Tier II reporting the same as TRI reporting? NO.
Wait, hold on, one last time to point out the main differences:
Tier II Community Right-to-Know Reporting | TRI Reporting | |
What needs to be reported? | Hazardous materials or chemicals, identified by having an SDS (MSDS) for them | Toxic chemicals, from the USEPA List of Lists |
Chemical use? | Stored at any one time in excess of the reporting quantity | Manufactured, processed or used over the course of a calendar year in excess of the reporting quantity |
Thresholds for reporting? | 10,000 pounds at any point in time, although some may have lower thresholds | 25,000 pounds over the course of the year for manufacture or process, 10,000 pounds for otherwise use. Some chemicals have MUCH lower thresholds for reporting (check!) |
Reporting deadline? | March 1st of each year | July 1st of each year |
So, now, what’s the answer?
Unequivocally, the answer is NO, they are not the same. Different things, different threshold amounts, different reporting, different deadlines. One does not count for the other, and if you need to do both, you need to do both.
To learn more about these two very different hazardous materials reporting regulations, click here to contact us or give us a call at 609-693-8301 to discuss your facility's needs today.
Tags: TRI Reporting, Environmental Compliance, Tier II Reporting
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