First a reminder for your EHS compliance calendar. The due date for Tier II reporting is March 1, 2021. Now, ask your team and everyone else who’s contributing to your Tier II efforts, “Are we on track?”
If you’re on schedule, our compliments. If you aren’t, Encamp is here to help. At this point, hitting the Tier II reporting deadline for 2021 might require better efficiency in your preparations. Ensuring EHS compliance could also require a sharper focus on details. Come March 1, your Tier II reports must be completed and submitted accurately, as well as on time.
Tier II reporting resources and best practices
Here are some resources we’ve prepared Tier II reporting, plus a few best practices to help ease the process. Our reporting cred? For one, Encamp is the largest third-party filer of EPCRA Tier II reports in the U.S. For another, most of us at Encamp come from EHS backgrounds and have filed thousands of Tier II reports.
So trust us when we say good luck. We’re pulling for you to hit the Tier II due date.
From Encamp’s Tier II Guide ‒ A Practical Guide for Tier II Reporting. This guide includes details on who must report and how to comply. It also addresses common problems with things like mixtures and state reporting requirements. Other sections cover common reporting errors and the latest updates to state and federal requirements.
The Guide’s final section additionally offers these Tier II reporting tips.
- Download the Ultimate Tier II Checklist from Encamp. It’s free!
- Find out if your state has changed any of its reporting requirements, such as thresholds. Also see if the state has made changes to its reporting portal, LEPC contact info, etc.
- If your state requires files to be in the EPA’s Tier2 Submit format, download the newest version of the Tier2 Submit Software.
- Gather all associated purchasing records and other inventory information to compile your Tier II data.
- Ensure there are no new products to add to your inventory from last year. If there are, your state may require the Safety Data Sheet (SDS) to be submitted as well.
- Also check to see if you’ve stopped storing any chemicals so you can remove them from your reporting.
- If your state requires a site plan, be sure to update that if needed. Note any and all changes in chemical storage location or other requirements.
- Compare your Tier II report to last year’s and see if they’re similar in amounts and chemicals. If there are considerable differences, be sure to review those and make any necessary changes.
Other helpful tools from the Encamp Resource Center
EPCRA Applicability Flowchart. Track Tier II applicability all the way to the county and city level.
Tier II Insight: Hazardous Chemical Inventories (blog). Learn how to inventory hazardous chemicals the “right way.”
10 Helpful Resources for Tier II Reporting and Compliance (blog). Access the EPA’s most helpful web pages and tools for Tier reporting, plus industry websites that focus on EHS compliance.
Encamp Product Focus: Making Tier II Submissions Easier (blog). Read how Encamp’s EHS software helps you better understand Tier II requirements, from the perspective of some of our customers.
Encamp’s Tier II Dashboard. Making Reporting Fast, Simple, Accurate (blog & video). Read about and watch how Encamp’s Tier II Dashboard streamlines Tier II reporting and keeps the process in full view.
Lead Acid Battery ebook. A detailed interactive guide on the ins and outs of lead-acid batteries, including when they’re subject to Tier II reporting.
Beyond EHS software
EHS compliance software like the cloud-based platform from Encamp certainly accelerates the Tier II reporting process. But so does your EHS team and how they function as a group — particularly if you’re all still working remotely due to the coronavirus pandemic.
Remote or not, here are a few more useful practices to help you meet this year’s Tier II reporting deadline. Remember, it’s March 1.
- Get everyone on the same Tier II path. This means an EHS director, EHS staff, and any contributors from throughout the business who gather and maintain data, such as purchasing records and inventory information. Even when final reports fall to one or two people, Tier II reporting is a group process.
- Provide structure with checklists and playbooks. Within a Tier II workflow, every person should know what’s expected by way of their role, local and federal regulations, scheduled tasks, and internal deadlines ahead of March 1. Checklists and playbooks can further help ensure reporting accuracy by keeping details from slipping through the cracks.
- Meet often and communicate like clockwork. Meet on-demand when something needs to be done or resolved right now. Hold weekly status and planning meetings, along with daily standup meetings, to keep reporting work moving and monitor its progress.
- Set Tier II reporting goals per team member. Break the process into goals for each EHS specialist and set deadlines for each goal. Team members should abide by playbooks and checklists when you have them.
- Share documents and work visibly. The first key is having an effective document storage hub in place. The second is creating an environment in which all users can access, review, and edit documents as a group.