An Industry Icon Talks Tier II

As a follow-up to an earlier post, I asked Dennis M. Patrick, M.S., CIH, CSP, CHMM and principal of the Environmental Planning Group, Ltd. out of Ashley, Michigan to fill us in on the uses of EPA Tier II forms by emergency personnel. Mr. Patrick is a Board Certified Industrial Hygienist and Hazardous Materials Consultant, and is well known and well established enough to even work from the front porch of his own log home when he's not out traveling the country providing insight to people in the hazardous materials industry.
My over-riding reason to interview him on this was to explore regulatory filings containing information helpful to emergency responders. Here's what he had to say:
Tier II Reporting and what Firefighters Need to Know Too!
from an interview with Dennis Patrick, , M.S., CIH, CSP, CHMM
Most people are familiar with the term Right to Know (called the Hazard Communication Standard) which in a nutshell says that employees in the workplace need to be advised of the hazards they encounter while working on the job for 40 hours a week. However, many are not familiar with the Community Right to Know Law and associated reporting referred to as Tier II, whose aim is to protect the community from chemical leaks, fires, explosions, incidents and the emergency response personnel who respond to these chemical and gases incidents. Tier II Reporting provides the facility specific hazard information needed by local hazardous materials responders such as police, fire and hazardous materials teams to protect the community in which the facility is located.
In the event of a chemical emergency at a facility, it is very important for the emergency responders to know what is on the inside, however unless you are a trained firefighter, most people would not know why this is the case and have a difficult time in understanding the risk that firefighters walk into everyday as part of their job.
The firefighter needs two things from the facility owner, the first is the Tier II form which is an inventory of chemicals on site and a Material Data Sheet from the manufacturer, which lists key physical, chemical aspects of the chemical and recommends appropriate personal protective equipment .
The Emergency Response Guidebook is used by the First Responders during the initial phase of a dangerous goods or hazardous materials transportation incident. This book relies on a couple of facts to decrease the amount of risk associated with such a response, first because of DOT designations such as flammable, oxidizers, inhalation hazards, toxic gases----the emergency responders can look at the containers long distance and decide on the best way of dealing with the incident and, secondly they (if it is available, consult the Hazardous Materials Manifest for the shipment. In an attempt to reduce risk as much as possible our firefighters rely on information found on Tier II forms for this vital information.
Currently there are over 1 million different chemicals that have come from the minds of men, if you stop to think about it---- how does a fire fighter or the Incident Commander know what he or she is dealing with when approaching a chemical incident or release? The answer is they need accurate information that is to be filled out on the Tier II form, with the following guidelines.
The physical and chemical characteristics of the chemicals are essential information that needs to be on the form, in my experience, facility owners do not always give a 100% effort when completing this form which can place the firefighters and community at risk. For instance it is very important that the firefighter know if the chemical is a flammable, an oxidizer, a corrosive, or a reactive; or if it a pure product, a gas, a liquid or a solid, or if can constitute a threat such as a fire hazard, a sudden release of pressure, or if it is immediately acute.
Add to this the potential for which portions of the body may be affected by exposure to a chemical such as the skin, the eyes or the respiratory system and you can appreciate the challenge facing every firefighter daily that is sent in to contain and extinguish a fire.
The Tier II submission must include required information on the form for each hazardous chemical present at your facility in quantities equal to or greater than established threshold quantities. For most states the following amounts are utilized; however some state have lower reporting thresholds for EHS and MSDS chemicals.
1.0 Extremely Hazardous Substances as designated under Section 302 of Title II, the reporting threshold is 500 lbs or the Threshold Planning Quantity whichever is lower.
2.0 MSDS chemicals, which includes all other chemicals for which facilities are required to have or to prepare an MSDS, with the minimum reporting threshold of 10,000 lbs.
If you have, questions, Mr. Patrick can be reached at EPG, Ltd. 989-838-2331. His email address is: