TIER II CHEMICAL INVENTORY FORM A PREPLANNING RESOURCE
BY ERIC G. BACHMAN
Annually fire departments are inundated with Tier II chemical inventory forms. Depending on the complexity of a fire district, the number of forms received can be overwhelming. These forms can provide valuable site-specific information, yet too often they are overlooked and filed away. Although many people perceive the Tier II chemical inventory form more as a nuisance than an asset, when used properly for response preparedness, it can be a lifesaver.
Tier IIs offer a fire department useful information about the contents within a facility. A heavy workload, a lack of time, or a shortage of personnel may prevent departments from using these forms as effectively as they could be for training and preincident surveys. But perhaps the primary reason for their not being used to maximum advantage is that fire department personnel do not fully understand the intent and significance of the form or the interpretation of the codes on the form. Tier II forms are an important resource and should be part of a department`s preincident survey program.
MANDATED LEGISLATION
Although it has been more than a decade since the advent of the Superfund Amendments and Reauthorization Act of 1986, also known as SARA, the legislation requiring the Tier II chemical inventory report form, it appears that industry and the emergency services are still learning. Part of the SARA provisions is the Emergency Planning and Community Right-to-Know Act (routinely referred to as Title III). This legislation requires that governmental agencies and business and industrial facilities report hazardous materials and plan for hazardous-materials emergencies.
Title III is broken down into three subtitles. Subtitle B, which is broken down into three subtitles, covers reporting requirements. Section 312-Emergency and Hazardous Chemical Inventory Forms, establishes guidelines for completing Tier I and Tier II forms. Since fire departments encounter the Tier II form more often, this form only is discussed in this article.
REPORTING REQUIREMENTS
By March 1 of every year, facilities that have on-site certain chemicals above a preestablished threshold quantity must submit a Tier II chemical inventory form. This form offers valuable information. However, the coding for the items provided may not be available for translation. A facility must report any chemical that requires an OSHA (Occupational Safety and Health Administration) material safety data sheet (MSDS) when at or in excess of 10,000 pounds at any time during the preceding year. Also, other chemicals known as “Extremely Hazardous Substances (EHS)” in quantities of 500 pounds or at a chemical specific Threshold Planning Quantity (TPQ), whichever is less, must be reported. EHSs and TPQs will be reviewed later.
INTERPRETATION OBSTACLES
Besides the chemical name and quantity, other site- and chemical-specific information must be given on the form, including the physical state, physical and health hazards, and storage conditions. Because of space limitations, codes and other symbols are in place. Unfortunately, many fire departments are not aware of the significance of these codes and, therefore, do not understand the form completely. They may know the chemical name but not the amount and storage conditions. This situation can create a response and training hazard to the department in that it will not be prepared for the potential.
TIER II FORM COMPONENTS
The following overview will answer some of those questions you may have. Some of the information is provided for the State Emergency Response Commission (SERC) and other regulating environmental agencies.
Facility Identification, Owner/Operator Name and Emergency Contact. These fields are self-explanatory.
SIC Code. This refers to the Standard Industrial Classification code. Each number represents a specific business or industry. For example, a SIC code of 2011 is a meat-packing plant, and a 5540 represents a gasoline service station. Fire departments need not be concerned with this field, which generally pertains to state and other regulatory agencies.
Dun & Bradstreet Number. This is a facility identification registration number. Not all facilities have one. Fire departments need not be concerned with this field, which pertains more to state and other regulatory agencies.
CAS. This stands for “Chemical Abstract Service,” a number classification system for chemical manufacturers and users; it is similar to the Dewey Decimal System used in a library.
EHS. This denotes “Extremely Hazardous Substance,” a chemical that can have immediate life-threatening effects on exposure. The Environmental Protection Agency (EPA) lists it separately. There are approximately 360 EHS chemicals. A facility with a specific quantity of an EHS may fall within special off-site planning requirements, known as the “Threshold Planning Quantity (TPQ).” TPQs vary from chemical to chemical. For example, the following quantities would require that a facility develop an off-site emergency response plan: 100 pounds of gaseous chlorine, 500 pounds of ammonia, and l,000 pounds of sulfuric acid.
Physical and Health Hazards. Five general hazards [Fire, Sudden Release of Pressure, Reactivity, Immediate (acute), and Delayed (chronic)] are listed. These hazards are general and do not provide specific characteristics.
Inventory. Maximum and average weight ranges in pounds are to be listed. The maximum range applies to the highest quantity that can be found in the facility at any one time. Average refers to what is usually on-site. The other entry in this section, Days on Site, obviously refers to the length of the period the material is on-site. Inventory codes are as follows:
Storage Codes and Locations
Container Type. This is designated by a letter from “A” to “R.” Each letter represents a different storage container from “A,” Above Ground Storage Tank, to “F,” Can, to “Q,” Railcar. The storage codes are listed at left.
Pressure (at which material is stored). The three numbered pressure classes given are as follows:
1. Ambient Pressure (atmospheric pressure).
2. Greater than Ambient Pressure (greater than atmospheric pressure).
3. Less than Ambient Pressure (less than atmospheric pressure).
Temperature (at which material is stored). Four temperature classes are listed (numbers 4 to 7):
4. Ambient Temperature (room temperature).
5. Greater than Ambient Temperature (higher than room temperature).
6. Less than Ambient Temperature but not cryogenic (refrigerated).
7. Cryogenic conditions (below 11507F).
OPTIONS
The facility has other informational options, including attaching a site plan, a list of site coordinate abbreviations, or a description of dikes and other safeguard measures. Again, this is optional and will be designated in the field in the lower right corner. This information should also be included in training and preincident surveys.
CONSIDERATIONS
When using the Tier II information for training and preincident surveys, consider the following:
1. The information reported is for the previous calendar year. A Tier II report received in 1996 represents chemical inventories for the 1995 calendar year. Depending on the situation, the information could be inaccurate.
2. Facilities are required to report non-EHS chemicals when in quantities of 10,000 pounds or more. Therefore, a facility may have many hazardous chemicals (that are not ESHs) in quantities of less than 10,000 pounds and do not have to report them.
3. There are exemptions from reporting, including food, food additive, food coloring, drug, and cosmetic regulated by the FDA (Federal Drug Administration).
4-7. The following substances may be excluded from reporting:
–Any substance present as a solid in any manufactured item to the extent exposure to the substance does not occur under normal conditions of use.
–Any substance to the extent it is used for personal, family, or household purposes or is present in the same form and concentration as a product packaged for distribution and use by the general public.
–Any substance to the extent it is used in a research laboratory or a hospital or other medical facility under the direct supervision of a technically qualified individual.
–Any substance to the extent it is used in routine agricultural operations or is a fertilizer held for sale by a retailer to the ultimate customer.
8. The inventory codes are not exact and can influence an incident or preparing for one if the quantity is misunderstood.
USES
When you receive a Tier II, review it comprehensively and use it as a training tool for your officers and firefighters. Contact the facility to schedule a preincident survey to get a hands-on view of chemical storage and facility layout. Use the form and the tour to assess your department`s ability to respond to and mitigate an incident that might occur there. You will be able to identify response limitations and the resources you will need. It may not be feasible or cost effective for your department to maintain a certain resource, but you must know what resources may be needed and are available, where to get the resources you don`t have, and how to get them to the incident site in times of an emergency.
The Tier II form is a valuable resource for identifying hazards. When used properly, it is an excellent resource for training firefighters, identifying response limitations, and identifying needed resources before an incident occurs. Too often, however, we make excuses for not reviewing them. But, there are no excuses for compromising public, environment, and firefighter safety. Ignoring or just filing these forms away is doing just that. If something goes wrong, the public has the “Right to Know” why.
If you have any questions on SARA Title III, contact your Local Emergency Planning Committee or your County Emergency Management Agency.
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ERIC G. BACHMAN, a 15-year veteran of the emergency services, is a former chief of the Eden Volunteer Fire/Rescue Department in Lancaster County, Pennsylvania, and the hazardous materials planner for the County of Lancaster Emergency Management Agency. He has an associate`s degree in fire science, advanced state of Pennsylvania certification in emergency management, and certifications in hazardous materials response and incident management. He is a member of and the public information officer for the Local Emergency Planning Committee as well as a member of the Haz Mat 2 Environmental Fire Rescue Co., Inc.
