Both Tier II Community Right-to-Know Reporting and TRI Reporting can be confusing. From what we've heard customers of ours tell us, there are so many aspects of reporting that sound similar or seem similar, that it's hard to keep track of them.
The issue is, when it comes to EPCRA Reporting, there's never been a time where you're under the microscope more than you are now. From 3rd party environmental groups getting aggressive, the cash-strapped governmental agencies cracking the whip, your operation needs to be 100% on top of these regulations, no matter what.
When it comes to staying on top of these regulations, there's a ton of confusing, contradictory, or straight up wrong information out there.
Regulators use the terms chemicals, materials, mixtures, and compounds interchangeably, which is not only wrong but very confusing. Some folks call the terms different things, others call them annual chemical inventories, and others just call them EPCRA Reporting, which while correct, is like saying "I drive a car". Obviously, we know the difference between a Hyundai and a Lamborghini, so why not clarify what you mean?
We cover this topic more in-depth in our article TRI Reporting vs Tier II Reporting which I encourage everyone to check out to learn more about these subjects.
So, let's get into these two subjects and learn more.
TRI Reporting needs to happen at your location assuming the following conditions are met:
TRI Reporting is overseen by the USEPA, so there's nothing specific for folks in North Carolina to worry about. Unlike some other states, North Carolina does not have any additional specific state requirements you need to be aware of. However, you do need to know that reporting can only be completed electronically via the internet over the USEPA's CDX (Central Data Exchange) software.
We've heard it called every name under the sun, but these tend to be the most common:
Regardless of what you call it, it's all the same thing.
While we're on the subject, here's some extra information you may find helpful on TRI Reporting.
Unlike TRI Reporting, Tier II CRTK Reporting is way more straightforward. I like to tell folks this is just a "snapshot" of your operation, and this information is useful in the hands of emergency responders.
The reason I say snapshot is because Tier II Reporting should reflect what your operation looks like on any standard day. Imagine if there's a fire at your operation. The local fire department would be able to pull up information about your operation and say they have tanks of chemical XYZ. This information helps your local community know what you have, so in the case of an emergency they can respond appropriately, or in the case of citizens, they can decide what they do (or don't) want to live near.
Remember a few years back there was that explosion at that fertilizer plant in Texas? Tier II Reporting lets your community know you have stuff on-site that could potentially be dangerous, and hopefully avoid accidents like what happened in Texas.
Let's look at the details of what Tier II Reporting is.
Once you determine if you have to report, you give your information electronically to:
Pretty easy, but there are a few things to remember:
Remember we said we hear people call regulations this, that, and the other thing? Well, this regulation has a few names, but they all mean the same thing.
It's all the same reporting, the same regulation, and it's the same everywhere you go across the country.
Here are a few articles that may be of interest to help you with Tier II Reporting.
Our number one recommendation to everyone is this: stay educated on the subjects.
Our number two recommendation is: don't wait til the last minute. Make sure you know TRI Reporting & Community Right to Know Reporting Deadlines to ensure you stay ahead of the game.
And always, if you aren't sure what you're doing, get in touch with experts to find out more.