The Tech Box

EPCRA – Tier II Reporting for Box Plants

September 19, 2023

EPCRA (Emergency Planning and Community Right-to-Know Act) requires certain facilities, including box plants, to submit an annual inventory of hazardous chemicals stored on-site to the State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC), and the local Fire department. Here are the steps to follow for EPCRA - Tier II reporting for box plants:

1. Determine if reporting is required: Box plants that meet the following criteria are required to file a Tier II report:

  • Store hazardous chemicals in quantities equal to or exceeding the established threshold levels (10,000 pounds for most chemicals, 500 pounds for extremely hazardous substances).
  • The facility is not exempt under Section 311(e)(5) of EPCRA (e.g., retail facilities, small manufacturers, or processors).

2. Identify hazardous chemicals on-site: Compile a comprehensive list of all hazardous chemicals stored at the box plant. This includes common chemicals used in the manufacturing process, such as adhesives, coatings, solvents, and cleaning agents. This information can be found in section 2 of the Safety Data Sheets (SDS).

3. Determine reporting thresholds: Review the reporting thresholds for each hazardous chemical to determine if it exceeds the established threshold levels mentioned above.

4. Obtain SDSs: Collect SDSs for all hazardous chemicals stored on-site. SDSs provide detailed information about the chemical composition, hazards, and safe handling procedures.

5. Compile necessary information: Gather the following information for each hazardous chemical:

  • Chemical name and Chemical Abstracts Service (CAS) number
  • Quantity stored on-site
  • Physical and health hazards
  • Storage location within the facility

6. Fill out the Tier II reporting form: Use the Tier II reporting form provided by the SERC or the appropriate regulatory agency in your state. Include all the required information for each hazardous chemical.

7. Submit the report: File the Tier II report with the SERC, LEPC, and the local fire department by the deadline. Check with your state or local agencies for specific submission instructions and deadlines. Some states may require electronic submission through their designated online reporting system.

8. Maintain records: Keep a copy of the filed Tier II report and supporting documentation (such as SDSs and inventory records) for at least three years. These records may be subject to inspection by the regulatory agencies.

9. Annual updates: Review and update the Tier II report annually to reflect any changes in hazardous chemicals stored on-site, quantities, or storage locations.

It is important to note that EPCRA requires facilities to make certain information available to the public, including emergency responders, upon request. This typically includes providing access to the Tier II report and chemical inventory information.

For additional guidance and specific requirements, the FBA website provides an FAQ for SARA Title III obligations with information on Sections 301-304 and 311-312. Refer to the EPCRA regulations and contact your state or local regulatory agency responsible for EPCRA compliance. They can provide further instruction and assist with any questions related to Tier II reporting for box plants.

Thanks,
Chase

Chase Kammerer is the Technical Services Manager at Fibre Box Association (FBA). If you have technical questions about the corrugated industry, you can reach him directly at ckammerer@fibrebox.org.