When is it due?
1 March each year, covering the preceding calendar year. The date does not move.
KODAEnvironmental
EPCRA · due 1 March
Tier II is the filing most often done at the last minute, because the inventory data sits in several places at once and nobody owns pulling it together until February. The work is not difficult. It is just tedious, and it has a hard date on it.
What actually matters
Where this one
goes wrong
01
The data is already partly ours
Where KODA handles your material, the waste side of the inventory comes out of records we already hold rather than out of a year of filed paperwork. That is the part that usually takes the longest.
02
You certify it, and that is correct
The certifying official has to be the owner, operator or their authorized representative. We prepare the submission and put it in front of that person complete, rather than asking them to assemble it.
03
The fire department copy gets missed
Tier II goes to three places, not one. The state receives it, the local emergency planning committee receives it, and the fire department with jurisdiction receives it. Missing the third is one of the more common findings.
04
Next year is easier than this year
Most of a Tier II is the same as last year's. Once the first one is built properly, the annual exercise becomes a review of what changed rather than a rebuild.
What we need from you
To start
- Chemical inventory for the site across the reporting year
- Safety data sheets for what was on site
- Maximum and average amounts held, and where each was stored
- Storage types, pressures and temperatures
- Site plan or storage locations, and the facility contacts
What you get back
To file
- A completed Tier II submission ready for certification
- The supporting inventory in a form you can check line by line
- The state, LEPC and fire department distribution handled
- A copy of everything filed, kept for the following year
Deadline
1 March, for the preceding calendar year
KODA prepares the submission. Your authorized official certifies and files it — that is how the requirement is written, and anyone telling you otherwise is describing it loosely.
Questions
Asked most often
Who signs it?
The owner, operator or their authorized representative. That cannot be us, and nobody offering to sign it for you is describing the process accurately. We prepare the submission; your official certifies and files it.
What if we are not sure we have to file?
Applicability turns on what was on site and in what quantity, and the answer is sometimes no. That is worth establishing before February rather than during it, and it is a short conversation either way.
Also handled
Other filings
Form R · due 1 July
TRI reporting and Form R preparation
Form R, built from throughput and waste data rather than reconstructed each spring.
State & federal waste reportsAnnual waste summaries and biennial reports
Annual and biennial waste reports, assembled from manifest data rather than rebuilt.
Phase I & Phase IIPhase I and Phase II environmental site assessments
Assessments for transactions, closures and financing — written to be relied on.
Start before the deadline,
not on it
Tell us which filings you carry and we will tell you what we would need and when we would need it.