Tier 2 - Hazardous Chemical Inventory Reporting (EPCRA Sections 311-312)
Section 311 and 312 (Tier 2 reporting) of the Emergency Planning and Community Right-To-Know Act (EPCRA) applies to facilities that must prepare or have available a Safety Data Sheet (SDS) for hazardous chemicals and those chemicals are over the reporting threshold quantity.
Tier 2 reporting is an annual inventory due March 1st of the hazardous chemicals a facility had at any point over reporting thresholds in the previous year.
Section 311 requires facilities with hazardous chemicals over the reporting threshold to provide an initial notification of the hazardous chemicals they have on site and whenever a new hazardous chemical becomes reportable at their location.
Both are important information to provide so emergency responders and emergency planners are able to make informed decisions for the safety of the community.
If you have any questions please contact Simon Stecker at 515-783-7346 or email iowa.epcra@dnr.iowa.gov.
List items for Tier 2 - Hazardous 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:
Exemptions: Some hazardous chemicals and facilities are exempt from reporting. See the Exemptions to Reporting document for 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. Start at E-Plan, it will generate a Tier 2 PDF once you have completed your submission.
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.
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.
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.
