Tier II Instructions


Chemical Inventory
Tier Two Instructions
Tier Two Form



When To Submit This Form.

Owners or operators of facilities that have hazardous chemicals on hand in quantities equal to or greater than set threshold levels must submit the Tier II form by March 1.

Where To Submit This Form.

Send a completed Tier II form to each of the following organizations:



Your State Emergency Response Commission

    Bureau of PENNSAFE
PO Box 68571
Harrisburg, PA 17106-8571
Telephone (717) 783-2071



Your Local Emergency Planning Committee.


Erie County Emergency Management Agency
2880 Flower Road
Erie, PA 16509
Telephone (814) 451-7920
FAX (814) 451-7120
E-mail lepc@ecdops.org



The fire department with jurisdiction over your facility.

If a Tier II form is submitted in response to a request, send the completed form to the requesting agency.
Any owner or operator who violates any Tier II reporting requirements shall be liable to the United States for a civil penalty of up to $25,000 for each such violation. Each day a violation continues shall constitute a separate violation.
If your Tier II responses require more than one page use additional forms and fill in the page number at the top of the form.

Reporting Period.

Enter the appropriate calendar year, beginning January 1 and ending December 31.


Facility Identification.

Enter the full name of your facility (and company identifier where appropriate).
Enter the full street address or state road. If a street address is not available, enter other appropriate identifiers that describe the physical location of your facility (e.g., longitude and latitude). Include city, county, state, and zip code.
Enter the primary Standard Industrial Classification (SIC) code and the Dun & Bradstreet number for your facility. The financial officer of your facility should be able to provide the Dun & Bradstreet number. If your firm does not have this information, contact the state or regional office of Dun & Bradstreet to obtain your facility number or have one assigned.


Enter the owner's or operator's full name, mailing address, and phone number.


Emergency Contact.

Enter the name, title, and work phone number of at least one local person or office who can act as a referral if emergency responders need assistance in responding to a chemical accident at the facility.
Provide an emergency phone number where such emergency information will be available 24 hours a day, every day. This requirement is mandatory. The facility must make some arrangement to ensure that a 24 hour contact is available.

Identical Information.

Check the box indicating identical information, located below the emergency contacts on the Tier II form, if the current chemical information being reported is identical to that submitted last year. Chemical descriptions, hazards, amounts, and locations must be provided in this year's form, even if the information is identical to that submitted last year.


Chemical Information

Description, Hazards, Amounts, and Locations.

The main section of the Tier II form requires specific information on amounts and locations of hazardous chemicals, as defined in the OSHA Hazard Communication Standard.
If you choose to indicate that all of the information on a specific hazardous chemical is identical to that submitted last year, check the appropriate optional box provided at the right side of the storage codes and locations on the Tier II form. Chemical descriptions, hazards, amounts, and locations must be provided even if the information is identical to that submitted last year.

What units should I use?

Calculate all amounts as weight in pounds. To convert gas or liquid volume to weight in pounds, multiply by an appropriate density factor.

What about mixtures?

If a chemical is part of a mixture, you have the option of reporting either the weight of the entire mixture or only the portion of the mixture that is a particular hazardous chemical (e.g., if a hazardous solution weighs 100 lbs. but is composed of only 5% of a particular hazardous chemical, you can indicate either 100 lbs. of the mixture or 5 lbs. of the chemical). The option used for each mixture must be consistent with the option used in your Section 311 reporting.

Because EHSs are important to Section 303 planning, EHSs have lower thresholds. The amount of an EHS at a facility (both pure EHS substances and EHSs in mixtures) must be aggregated for purposes of threshold determination. It is suggested that the aggregation calculation be done as a first step in making the threshold determination. Once you determine whether a threshold for an EHS has been reached, you should report either the total weight of the EHS at your facility, or the weight of each mixture containing the EHS.

Chemical Description

1. Enter the Chemical Abstract Service registry number (CAS). For mixtures, enter the CAS number of the mixture as a whole if it has been assigned a number distinct from its constituents. For a mixture that has no CAS number, leave this item blank or report the CAS numbers of as many constituent chemicals as possible.
If you are withholding the name of a chemical in accordance with criteria specified in Title III, Section 322, enter the generic class or category that is structurally descriptive of the chemical (e.g., list toluene diisocyanate as organic isocyanate) and check the box marked Trade Secret. Trade secret information should be submitted to EPA and must include a substantiation. Please refer to EPA's final regulation on trade secrecy (53 FR 28772, July 29, 1988) for detailed information on how to submit trade secrecy claims.

2. Enter the chemical name or common name of each hazardous chemical.

3. Check box for ALL applicable descriptors: pure or mixture; and solid, liquid, or gas; and whether the chemical is or contains an EHS.

4. If the chemical is a mixture containing an EHS, enter the chemical name of each EHS in the mixture.


You have pure chlorine gas on hand, as well as two mixtures that contain liquid chlorine. You write "chlorine" and enter the CAS number. Then you check "pure" and "mix" -- as well as "liquid" and "gas.

Physical And Health Hazards.

For each chemical you have listed, check all the physical and health hazard boxes that apply. These hazard categories are defined in 40 CFR 370.2. The two health hazard categories and three physical hazard categories are a consolidation of the 23 hazard categories defined in the OSHA Hazard Communication Standard, 29 CFR 1910.1200.
Hazard Category Comparison For Reporting Under Sections 311 and 312



EPA's Hazard Categories

Fire Hazard
Release of Pressure 
Reactive Immediate (Acute)
Delayed (Chronic)


OSHA's Hazard Categories

Combustion Liquid
Oxidizer Explosive
Compressed Gas Unstable Reactive
Organic Peroxide
Water Reactive
Highly Toxic

Other hazardous chemicals with an adverse effect with short term exposure

Other hazardous chemicals with an adverse effect with long term exposure

Maximum Amount

1. For each hazardous chemical, estimate the greatest amount present at your facility on any single day during the reporting period.
2. Find the appropriate range value code in Table 1.
3. Enter this range value as the Maximum Amount.


Table I - Reporting Ranges

Range Weight Range in Pounds



































1 billion

higher than 1 billion


You received one large shipment of a solvent mixture last year. The shipment filled five 5,000 - gallon storage tanks. You know that the solvent contains 10% benzene, which is a hazardous chemical.
You figure that 10% of 25,000 gallons is 2,500 gallons. You also know that the density of benzene is 7.29 pounds per gallon, so you multiply 2,500 gallons by 7.29 pounds per gallon to get a weight of 18,225 pounds.
Then you look at Table I and find that the range value 04 corresponds to 18,225. You enter 04 as the Maximum Amount.

Average Daily Amount

1. For each hazardous chemical, estimate the average weight in pounds that was present at your facility during the year. To do this, total all daily weights and divide by the number of days the chemical was present on the site.
2. Find the appropriate range value in Table I.
3. Enter this range value as the Average Daily Amount.


The 25,000 gallon shipment of solvent you received last year was gradually used up and completely gone in 315 days. The sum of the daily volume levels in the tank is 4,536,000 gallons. By dividing 4,536,000 gallons by 315 days on-site, you calculate an average daily amount of 14,400 gallons.

You already know that the solvent contains 10% benzene, which is a hazardous chemical. Since 10% of 14,400 is 1,440, you figure that you had an average of 1,440 gallons of benzene. You also know that the density of benzene is 7.29 pounds per gallon, so you multiply 1,440 by 7.29 to get a weight of 10,500 pounds.

Then you look at Table I and find that the range value 04 corresponds to 10,500. You enter 04 as the Average Daily Amount.

Number of Days On-Site

Enter the number of days that the hazardous chemical was found on-site.


The solvent composed of 10% benzene was present for 315 days at your facility. Enter 315 in the space provided.

Storage Codes and Storage Locations

List all non-confidential chemical locations in this column, along with storage types/conditions associated with each location. Please note that a particular chemical may be located in several places around the facility. Each row of boxes followed by a line represents a unique location for the same chemical.

Storage Codes: Indicate the types and conditions of storage present.

a. Look at Table II. For each location, find the appropriate storage type and enter the corresponding code in the first box.

b. Look at Table III. For each location, find the appropriate storage types for pressure and temperature conditions. Enter the applicable pressure code in the second box. Enter the applicable temperature code in the third box.

Table II – Storage Codes


Types of Storage


Above ground tank


Below ground tank


Tank inside building


Steel drum


Plastic or non metallic drum








Fiber drum








Glass bottles or jugs


Plastic bottles or jugs


Tote bin


Tank Wagon


Rail car



Table III - Pressure and Temperature Conditions


Storage Conditions




Ambient pressure


Greater than ambient pressure


Less than ambient pressure






Ambient temperature


Greater than ambient temperature


Less than ambient temperature but not cryogenic


Cryogenic conditions


The benzene in the main building is kept in a tank inside the building at ambient pressure and less than ambient temperature.
Table II shows you that the code for a tank inside a building is C.
Table III shows you that the code for ambient pressure is 1, and the code for less than ambient temperature is 6.
You enter: C 1 6

Storage Locations:

Provide a brief description of the precise location of the chemical, so that emergency responders can locate the area easily. You may find it advantageous to provide the optional site plan or site coordinates as explained below.
For each chemical, indicate at a minimum the building or lot. Additionally, where practical, the room or area may be indicated. You may respond in narrative form with appropriate site coordinates or abbreviations.
If the chemical is present in more than one building, lot, or area location, continue your responses down the page as needed. If the chemical exists everywhere at the plant site simultaneously, you may report that the chemical is ubiquitous at the site.

Optional Attachments:

If you choose to attach one of the following, check the appropriate Attachments box at the bottom of the Tier II form.

a. A site plan with site coordinates indicated for buildings, lots, areas, etc. throughout your facility. Note: A site plan Must be on file with the LEPC and the Fire Department.

b. A list of site coordinate abbreviations that correspond to buildings, lots, areas, etc. throughout your facility.

c. A description of dikes and other safeguard measures for storage locations throughout your facility.


You have benzene in the main room of the main building, and in tank 2 in tank field 10.
You attach a site plan with coordinates as follows:
main building = G-2
tank field 10 = B-6.
Fill in the Storage Location as follows: B-6 ( Tank 2 ) G-2 ( Main Room)

Confidental Information

Under Title III, Section 324, you may elect to withhold location information on a specific chemical from disclosure to the public.
If you choose to do so: Enter the word "confidential" in the Non-Confidential Location section of the Tier II form on the first line of the storage locations. On a separate Tier II Confidential Location Information Sheet, enter the name and CAS number of each chemical for which you are keeping the location confidential. Enter the appropriate location and storage information, as described above for non-confidential locations.
Attach the Tier II Confidential Location Information Sheet to the Tier II form. This separates confidential locations from other information that will be disclosed to the public.



Instructions for this section are included in the downloadable form.

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