Most facilities are not aware that the Hazardous Chemical Inventory Reporting requirements (Section 311-312 of the Emergency Planning and Community Right-to-Know Act [EPCRA]) are required to be entered into an annual online reporting system, run by the Louisiana State Police (LSP), called Tier II. The online reporting window begins each January and runs through the end of February. The time for filing last year’s inventory reports is now.
There are significant differences from the Federal requirements for reporting in Louisiana. These differences include the following:
- There is no lower limit for onsite personnel to have to report (EPA requires 10 full-time persons).
- While there are exemptions for retail/household chemicals and gasoline station facilities, the limit for a HAZARDOUS SUBSTANCE (which includes fuels) is 500 pounds onsite at anytime during the year. At 6.2-8.0 pounds per gallon for most liquids, this means about 60-80 gallons onsite of any hazardous substance or chemical will require a Tier II report for that site.
Note that commercial spray cans and small volume packaged materials are exempt. The LSP is mainly interested in which tanks, drums, and compressed air canisters might become a hazard during an emergency response and where those items are located on a facility. The purpose is to protect the public and emergency responders during a release, fire, or explosion.
- Once a facility decides to begin reporting Tier II reports, they must continue reporting or receive a substantial fine. There is an annual fee per facility, usually about $65-$85 per site.
- Filing is for the previous year (Jan 1-Dec 31) and takes place between January 1st and March 1st of the following year. Reporting is in pounds of chemicals or mixtures and is reported as a range (0-99, 100-999, 1000-9999, etc.). Once the Tier II report is set up, the designated person (onsite or consultant) logs on and edits the contacts, facility data, and reviews each chemical annually.
The purpose of the reporting is to assist first responders in knowing where hazards might be located and their amounts. It is in the facility’s best interest for first responders to understand the amount and locations of hazardous materials on their site when an emergency occurs. For more information on how to file these reports, contact Diana Munoz at Leaaf Environmental, LLC at (504) 841-9813 or firstname.lastname@example.org.