Tier 2, Form R, and Air Emissions Reports Due!

As in past years, RPS stands ready to assist our industry clients in ensuring compliance with upcoming regulatory deadlines for Tier II, Form R and Air Emissions Reports for reporting year 2020.

Dave Buchalter, Senior Vice President, Compliance

State and local authorities expect these reports to be both timely and complete, so now is a good time to prepare your data for any such reports that apply to your entity. These could include:

  • Tier II Hazardous Materials Inventory Report: Year 2020 Reporting Deadline is March 1, 2021:Facilities subject to EPCRA Section 312 must submit an emergency and hazardous chemical inventory report to their Local Emergency Planning Committee, the State Emergency Response Commission, and their local fire department. Most states now require submittal of Tier II report information using electronic software or online reporting systems such as EPA’s Tier2Submit, Tier II Manager, or E-Plan.
  • Hazardous Materials Business Plans: If you operate in the state of California, your HMBP recertification deadline may now be March 1, depending on your CUPA. Many CUPAs are now enforcing the state-mandated HMBP recertification deadline of March 1st, rather than using the HMBP “anniversary date” as your due date for recertification.
  • Air Emissions Report: Year 2020 Reporting Deadlines Varies by State: Under the Clean Air Act (CAA), EPA limits the quantity of air pollutants throughout the U.S. Most facilities with air permits must submit an annual air emissions summary report to quantify those emissions. 
  • Form R Reports: Year 2020 Reporting Deadline is July 1, 2021:Under Section 313 of EPCRA, certain businesses must report each year on the amounts of “Form R” chemicals their facilities released into the environment. (Note: Form R Reports can be filed in early 2021).

RPS assists many clients in addressing regulatory compliance programs and permitting. We can help you identify reporting requirements for operations or portfolio assets, answer questions about the applicability of the reporting requirements to your facility, and assist you in completing the reports. For more information, please contact: 

David Buchalter, P.E. 
Senior Vice President
Dave.Buchalter@rpsgroup.com
(404) 809-3863

Cheryl Horn, P.E. 
Vice President
Cheryl.Horn@rpsgroup.com
(423) 902-5336

Beth Fitzpatrick, TURP  
Senior Environmental Consultant 
Beth.Fitpatrick@rpsgroup.com
(401) 789-6224

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