Tier II Reporting: The Mistakes That Keep Showing Up

Every year, March 1 comes and goes, and facilities scramble to file their Tier II reports under EPCRA Section 312. And every year, I see the same problems.

The reporting itself is straightforward. You list the hazardous chemicals stored at your facility above the reporting thresholds (10,000 pounds for most chemicals, 500 pounds for extremely hazardous substances), along with maximum and average quantities, storage locations, and contact information. You file through your state's system — in Florida, that's E-Plan through the SERC.

Simple enough. But here's what goes wrong.

Only Reporting the Obvious

The most common issue I see is facilities that only report one or two chemicals — usually sulfuric acid in forklift batteries or diesel in a fuel tank — and ignore everything else on site. They file something, feel good about it, and move on.

Meanwhile, they've got 15,000 pounds of a raw material sitting in a silo that nobody thought to check. Or cleaning chemicals stored in a maintenance closet that individually are below threshold but aggregate across the site to well over 10,000 pounds. Or propylene glycol in a 2,000-gallon chiller system that's been there since the building was constructed.

If you haven't done a complete chemical inventory review for Tier II purposes — walking the floor, checking purchasing records, looking at SDSs — you're probably under-reporting.

Multi-Site Problems

Companies with multiple facilities in the same area sometimes file one report covering all locations. That's wrong. Each facility needs its own submission. The fire department that responds to a release at your warehouse on Main Street needs to know what's there, not what's at your office three miles away.

I've also seen the reverse: a company files for their main building but forgets about the second building across the parking lot that's on a different address but same site. If it's the same EPA facility ID, it should be on the same report. If it's a different address with separate operations, it might need its own.

Missing the Fire Department Pre-Plan

This one gets overlooked constantly. Part of the Tier II obligation is making sure your local fire department has the information they need to respond safely. That means not just filing the report, but making sure they have a pre-plan for your facility — where hazardous materials are stored, what quantities, special hazards, shut-off locations.

Some fire departments are proactive about this. Many aren't. If you haven't heard from your local FD after filing, reach out. Invite them for a walk-through. It's good practice regardless of the regulation.

Late Filing Is Still Filing

If you're reading this and you missed the March 1 deadline — file anyway. A late report is better than no report. The penalties for not filing are worse than the penalties for filing late, and in most cases, state agencies will work with you if you're making a good-faith effort to come into compliance.

The Florida SERC is at sercflorida.org. E-Plan is at erplan.net. Both are free. It takes about an hour once you have your chemical inventory in hand.

Just do it right the first time and you won't have to think about it again until next year.