Eagle Software provides a complete turnkey solution to completing your SARA Title III/Tier Two Reports. We address your individual needs when your chemical reporting requirements are complicated by multiple facilities. We have been helping oil and gas operators for over 30 years with their SARA filings. Call us to discuss yours!
Whether you are new to SARA Title III or experienced, we are here to help you understand what SARA Title III is and what it means you. The Emergency Planning and Community Right-to-Know Act of 1986 establishes requirements for federal, state and local governments and industry regarding emergency planning and “Community Right-to-Know” reporting on hazardous and toxic chemicals.
Reporting under Section 312 of the Community Right-to-Know Act, also known as SARA Title III or EPCRA, requires owners or operators of a facility to submit an emergency and hazardous chemical inventory to the State Emergency Response Commission, the Local Emergency Planning Committees, and the local fire departments with jurisdiction over the facility.
This inventory is submitted as a Tier Two report that must be filed by March 1st of each year. State and local agencies have the authority to modify reporting requirements as long as the minimum federal guidelines are being addressed. It is important that the owner or operator be familiar with the “Right-to-Know” laws and that the reporting procedure he decides to use satisfies state reporting requirements.
Hazardous chemicals covered by Section 312 are those for which facilities are required to prepare or have available safety data sheets (SDS) under Occupational Safety and Health Administration (OSHA) regulations and that were present at the facility at any time during the calendar year above specified thresholds.
Federal rules require reporting these hazardous chemicals if the inventory exceeds 10,000 pounds at any one time, and for extremely hazardous chemicals when the inventory exceeds 500 pounds or the Threshold Planning Quantity (TPQ) in the majority of states.
Many state commissions have additional requirements or have incorporated the federal contents into their own forms. For example, the State of Louisiana requires reporting under lower threshold quantities. It is important that the owner or operator be familiar with the “Right-to-Know” laws and that the reporting procedure he decides to use satisfies state reporting requirements.
The Tier Two reporting requirements are further complicated for multiple facilities that are located in several state, county, and fire department jurisdictions with each agency having its own forms and requirements. Eagle Software monitors the Right-to-Know laws throughout the year and updates our procedures to conform to any changes.
Reporting under Section 312 requires the owner or operator of a facility to submit their Tier II Data in various formats as follows:
• SERC: either upload an EDI file or input directly into the state’s website
• LEPC: either upload an EDI file or mail a hard copy
• Fire Department: mail a hard copy
We prepare not only the state reports, but also print and collate the copies required by the LEPCs and fire departments
Initial Tier Two reports required by Texas:
In addition to the annual Tier Two Report, Texas requires facility operators to submit an initial Tier Two Report and applicable fee within 90 days: