What is Tier II Reporting?
Under the federal Emergency Planning and Community Right to Know Act (EPCRA), facilities who manufacture, use, or store hazardous chemicals above certain amounts at any given time during the 2018 calendar year are required to submit reports on their chemical inventories.
Please be advised that under EPCRA (Title III of the Superfund Amendments and Reauthorization Act of 1986), any owner or operator who violates Tier II reporting shall be liable for a civil penalty of up to $32,500 for each violation. Each day a violation continues shall constitute a separate violation. In accordance with EPCRA, EPA has the authority to enforce violations of the statute.
Tier II Reporting Thresholds
|Extremely Hazardous Substances (EHS), as defined by EPA1||Greater than 500 pounds (277kg), or the Threshold Planning Quantity, Whichever is less|
|Any other Hazardous Chemical for which OSHA requires employers to maintain a MSDS or SDS sheet2||10,000 pounds (4,540 kg) or more|
1 US Title 40, Volume 27, Part 355, Appendix A
2 US Title 29, Volume 6, Part 1910, Subpart 1200
Extremely Hazardous Substances
Extremely Hazardous Substances (EHS) stored at or above the Threshold Planning Quantity (TPQ) require special planning activities and must be reported on a facility’s Tier II form. A complete listing EPA List of Lists March 2015
Who must I submit a Tier II Report to?
State, County, and Local Fire Department
Required facilities must file Tier II reports to the Pennsylvania Department of Labor and Industry, Bureau of Occupational & Industrial Safety, PENNSAFE Program on their website: http://www.lipatts.state.pa.us/submit
Additional information on submitting Tier II reports to PENNSAFE may be found by calling (717) 783-2071 or e-mail to: firstname.lastname@example.org
Schuylkill County LEPC requires “Exempt” facilities to file in order to capture data for planning purposes.
- Reporting to PENNSAFE using the web site for the PATTS system: http://www.lipatts.state.pa.us/submit
- Under this system, facilities will submit to the PATTS system. The County will receive the data electronically.
- Reports may be filed after 1/2/2019 and in time to process invoices and make payment prior to 3/1/2019. The reporting deadline is 3/1/2019.
- Facilities will be billed by both the state and the LEPC for the Tier II fees as applicable.
- On line filing meets the county LEPC requirements. Facilities should continue to submit a copy of the Tier II report to the local fire company.
How do I submit my Tier II report?
Facilities will only report to the state’s PATTS system, found at the following address: http://www.lipatts.state.pa.us/submit. Facilities who have not previously submitted Tier II reports will need to create a new user account. The LEPC will be able to retrieve facilities’ Tier II data from the state’s PATTS system. If you have any questions or issues concerning PATTS, please contact the PENNSAFE Program at: email@example.com or 1(717) 783-2071.
How do I pay my Tier II fees?
Once you have submitted and certified your Tier II report with the PATTS system, an invoice will be sent to the e-mail address you provided in the system. Please remit your invoice with a check or money order made payable to: Treasurer, Schuylkill County to the address on the invoice.
Tier II Reporting Documents