Pursuant to EPCRA Section 312, facilities must submit Tier II inventory information by March 1st every year. As part of this information, facilities must provide a brief description of the precise location of the chemical so that emergency responders can easily locate the area. How should facilities that have the chemical present in multiple locations report for this field?
At a minimum, the facility must indicate the building or lot where the chemical is located; however, the facility may indicate the specific room or area where practical. Facilities may also respond in narrative form with appropriate site coordinates, abbreviations, or a site plan. If the chemical is present in more than one building, lot, or area location, the facility should list each location as appropriate. If the chemical exists everywhere at the plant site simultaneously, facilities may report that the chemical is ubiquitous at the site.
Additional guidance for completing Tier II forms can be found in the Instructions for the Tier II Emergency and Hazardous Chemical Inventory Form, available at the following URL: