California Tier 2 Reporting is a vital compliance requirement for businesses that handle hazardous chemicals. Given the presence of numerous industries managing such materials, California has implemented a strict Tier II reporting process aimed at safeguarding public safety. The goal is to ensure transparency about the chemicals stored and used within facilities, promoting the protection of residents, emergency responders, and the environment. 

California prioritizes community safety and the right to know about potential chemical hazards while ensuring effective emergency preparedness. To support this, the state has implemented the Hazardous Materials Business Plan (HMBP) program. But what does this program involve, and which facilities are required to comply? Keep reading to learn more. 

 

What is Tier 2 Reporting? 

Tier 2 Reporting is part of the Emergency Planning and Community Right-to-Know Act (EPCRA). It requires facilities that store hazardous chemicals above certain thresholds to report their chemical inventory to local, state, and federal agencies. This information is critical for emergency preparedness and community safety. Facilities managing hazardous chemicals are required to submit these reports annually by March 1. The tier 2 report copies should also be mailed to the local emergency planning committee (LEPC), and fire department.  

 

 

Understanding California Tier 2 Reporting Requirements:

California Tier 2 Reporting follows federal EPCRA guidelines but adds state-specific requirements. Businesses must submit their hazardous chemical inventory through the California Environmental Reporting System (CERS). The report includes details like the type, quantity, and storage location of hazardous materials and recyclable items. The purpose of the Hazardous Materials Business Plan (HMBP) is to protect people and the environment from the risks linked to hazardous material storage or accidental release. By documenting these materials, emergency responders can take quick action to safeguard public safety. 

 

California Tier 2 Reporting: Some Vital Points:

  • Deadline: The annual deadline for California Tier 2 Reporting is March 1st. However, each local Certified Unified Program Agency (CUPA) sets its own deadlines. 
  • Reporting Threshold: Facilities must report if they store 500 pounds of solid, 55 gallons of liquid, or 200 cubic feet of compressed gas. 
  • Submission Platform: Reports must be submitted through the California Environmental Reporting System (CERS). 

 

What Information Needs to Be Reported? 

 

  • Storage Tanks: Report both aboveground and underground storage tanks containing hazardous materials. 
  • Recyclable Materials: Hazardous materials recycled on-site are exempt from reporting. 
  • Off-Site Recycling: If hazardous materials are sent to an off-site recycling facility, full reporting is required. 
  • Battery Reporting: Various types of batteries must be reported as per the guidelines issued in March 2022. 

 

Facilities required to submit California Tier 2 Reports include: 

  • Manufacturing plants 
  • Warehouses storing hazardous chemicals 
  • Laboratories and research facilities 
  • Agricultural operations using significant chemical quantities 
  • Fuel storage and distribution centers 

 

Did you Know? 

Following types of facilities must share the details mentioned below through the tier 2 reporting submission.  

  • Manufacturing Facilities: Need to report chemicals including acids, bases, solvents, coatings etc. 
  • Hardware Stores: Must account for chemicals such as paints, cleaning agents, fertilizers, and pesticides. 
  • Different Auto Repair Shops: Should include materials like brake fluids, paints, solvents, antifreeze, oils etc. in their hazardous materials plans. 
  • Gas Stations: Must report the presence of fuels like gasoline, diesel, and lubricating oils. 
  • Printing Shops: Are required to include hazardous materials such as inks, solvents, adhesives etc.  
  • Medical Facilities: Must report substances like medical gases, radioactive materials, disinfectants, and lab chemicals. 

 

What is California’s Electronic Tier II Reporting System (CERS)? 

 

The California Environmental Reporting System (CERS) is an online platform that allows businesses to submit their hazardous materials information. It helps businesses and regulatory agencies manage data more efficiently and ensures accurate and consistent reporting. In addition to California’s Tier 2 reporting, CERS can also be used for submitting the following: 

  • Underground Storage Tanks (USTs) 
  • Aboveground Storage Tanks (ASTs) 
  • Hazardous Waste Generation (Biennial Reports) 
  • Hazardous Materials Business Plans (HMBPs) 

 

California Tier II Report Submission Process 

Follow the steps below for an easy and simple tier 2 report submission process:  

  • Create a CERS Account: Register your facility on the CERS portal. In case you have an account simply log in. 
  • Start a New Tier II Report: Once logged in, go to the “Tier II” module and click on “Add New Tier II Report” for the reporting year you are working on. 
  • Choose your Facility and Reporting Year: Choose the facility you are reporting for and enter the calendar year of the chemical inventory. Then click on “Create Tier II” to proceed. 
  • Provide information about Facility and Chemical Information: Share contact details, chemical storage locations, and details about chemical inventory.  
  • Provide Chemical Details: 

For each chemical, include the following: 

  • CAS number 
  • Chemical name 
  • Physical state 
  • Storage types and locations 
  • Aggregate quantities on-site that exceed reporting thresholds 

 

1. Estimate Maximum Daily Amounts: If your chemical inventory fluctuated during the year, provide an estimate of the maximum daily amounts stored.

2. Attach Safety Data Sheets (SDSs): For each chemical listed, upload or link the corresponding Safety Data Sheets (SDSs) in CERS. 

3. Submit the Report: Review and submit the report before the March 1st deadline. 

4. Confirmation: Keep a record of the submission confirmation for compliance records. 

 

Important Reporting Requirement to Remember 

 

  • Update for Increased Hazardous Materials: If there is a 100% increase in the amount of hazardous material already reported, the HMBP must be updated within 30 days to reflect this change. 
  • Business Information Changes: Any changes in business or facility address, business ownership, or business name must be reported to your CUPA within 30 days. 
  • New Hazardous Materials: If your facility begins handling previously undisclosed hazardous materials that meet the inventory requirements, you must submit an update to the HMBP within 30 days. 
  • Major Operational Changes: This includes any alterations to how hazardous materials are stored, managed, or disposed of. 

 

Why is California Tier 2 Reporting Important? 

 

  • Public Health and Safety

    Tier 2 reports give emergency responders (like firefighters and police) essential details about the hazardous materials at a facility. This helps them respond quickly and safely during emergencies like chemical spills or fires by knowing what chemicals are on-site. 

  • Environmental Protection

    By reporting hazardous materials, Tier 2 helps identify potential risks to the environment. If chemicals spill or leak, local authorities can take quick action to protect the air, water, and soil from contamination. 

  • Regulatory Compliance

    California requires businesses to report hazardous materials through Tier 2, following both state and federal rules, like the Emergency Planning and Community Right-to-Know Act (EPCRA). Failing to report or underreporting can lead to fines or legal trouble. 

  • Emergency Planning and Response

    Tier 2 reports help local agencies create emergency plans that are specific to the chemicals in the area. This ensures that both emergency responders and the community are prepared for any chemical-related incidents. 

  • Worker Protection

    Tier 2 reporting helps businesses identify chemical risks and take steps to protect employees, such as providing safety training, personal protective equipment (PPE), or safety audits. This keeps workers safe from hazardous exposure.