Reporting Requirements

Reporting Hazardous Materials Inventories:

Tier II Reports

Under EPCRA, certain persons or businesses with hazardous chemicals or extremely hazardous substances are required to provide inventory information to the Missouri Emergency Response

Commission (MERC), their local fire department, and the Local Emergency Planning Committee (LEPC). Missouri has adopted the Tier II form as a means to comply with EPCRA.

Who must submit this form?
The owner or operator of a facility where hazardous chemicals are used, produced, or stored must submit a Tier II form if the quantity of hazardous chemicals on hand exceeds specific thresholds.

What chemicals must be reported?
Hazardous chemicals that must be reported include any substances for which a facility must keep material safety data sheets (MSDS) under OSHA's Hazard Communication Standard. If a facility has more than 10,000 pounds of a hazardous chemical on hand at any one time during the calendar year, the chemical must be reported on the Tier II form.

When are the Tier II report due?
The Tier II reports and fees are due annually by March 1. Local governments, family farms, and petroleum businesses who pay federal transportation fees are exempt from paying fees. Bulk fertilizers are also exempt. The fees are used to support LEPCs in their prevention and preparedness activities, hazardous materials response training, and to administer the program.

In addition, extremely hazardous substances as specified in 40 CFR Part 355 must be reported on the Tier II form if a facility has more than 500 pounds or the threshold planning quantity on hand at any one time during the calendar year.

Under Missouri law, explosives and blasting agents in excess of 100 pounds must be reported to the fire department within 24 hours of being present at a facility. If storage is longer than 15 days, these substances must be reported to the MERC, local fire department, and the LEPC. This requirement does not apply to materials in transit provided the carrier is in compliance with US Department of Transportation regulations.