Chemical Inventory Reporting

Facilities must report chemicals that meet or exceed the following thresholds:

• Extremely Hazardous Substances (EHS): 500 pounds or the Threshold Planning Quantity (TPQ), whichever is lower. EHS and their TPQs can be found here:
  • 40 CFR part 355 Appendix A
• Gasoline or Diesel at a Retail Gas Station:
  • Gas and Diesel at Retail Gas Stations, Tier 2 Reporting Guide
• All Other Hazardous Chemicals: 10,000 pounds.

Exemptions: Some hazardous chemicals and facilities are exempt from reporting. See Document for some of the common exemptions.

What is Tier 2 Reporting?

Tier 2 reporting (Section 312) is an annual hazardous chemical inventory form due March 1 each year. Reporting opens January 1.

Required information includes:

• Chemical Information such as quantities, storage locations, and hazards
• Facility information such as location, identification numbers, and general info
• Contact information such as two emergency contacts, one Tier 2 contact, and one owner/operator contact
  • One facility emergency coordinator contact if you report an EHS

How to Report a Tier 2?

You must ensure the Tier 2 report is submitted to the State Emergency Response Commission (SERC), the Local Emergency Planning Committee (LEPC), and the local fire department.

• SERC: The State of Iowa only accepts Tier 2 submissions through E-Plan
  • E-Plan - Hazmat Emergency Management System
  • How to report using E-Plan (video)
• LEPC: Refer to the county coordinator list to see how your county prefers to receive Tier 2 reports. If it says “mail to fire department only” that means your county utilizes E-Plan and doesn’t need a separate submission.
• Fire Department: We do not keep a tracking list of how fire departments prefer to receive Tier 2s. You can call them to check on their preferred method or email/mail it to them. The following fire departments have identified that they don’t need a separate submission from E-Plan.
  • Des Moines Fire
  • Dubuque Fire Department

Tier 2 Chemical Inventory Reporting Informational Sheet

What is a 311 notification?

A 311 notification requires an initial one-time notification that hazardous chemicals over the threshold reporting quantity are present at a facility. This applies to new chemicals on site over the threshold reporting quantity or chemicals that were increased to exceed the threshold reporting quantity.

How to submit a 311 notification?

Each newly reportable substance is required to be notified to the State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC), and the Fire Department within three months of it becoming reportable. The notification must either contain the SDS for each newly reportable hazardous chemical or a list of the newly reportable hazardous chemicals and their associated hazards. A Tier 2 can satisfy the notification requirement if it falls within the three-month window.

Here is how to submit to each entity:

• SERC: Email to iowa.epcra@dnr.iowa.gov
• LEPC: Email to the county contact on the county coordinator list
• Local Fire Department: Mail or email the notification. You can also call to check their preferred method.

Emergency planners and first responders are able to access Tier 2 chemical inventory data through E-Plan. E-Plan has the following tools and more to assist with emergency planning and response.

• Detailed information for a specific facility, and associated chemicals reported, on demand
• County wide excel lists of Tier 2 facilities and reported chemicals
• Maps of Tier 2 sites in a specific area
• Search by specific chemical to see how prevalent it is in your area

How to access E-Plan

To request an account, go to https://erplan.net/eplan/login.htm and click “Create First Responder Account”. Fill out the relevant information then put Simon Stecker or Adam Broughton as the authorizing user. Your request will be promptly reviewed and approved if determined appropriate for you to have access to Tier 2 data. Most users will be expected to only request county level access, if you request State level, Iowa DNR may inquire about reasoning.

• Environmental Protection Agency, EPCRA
• Environmental Protection Agency, EPCRA FAQs
• 40 Code of Federal Regulations (CFR) Part 370
• Lead Acid Battery Reporting Guide