Storage location for batteries in forklifts when complying with Tier II reporting
As part of Tier II Chemical Inventory Reporting, a facility must provide a brief description of the precise location of the hazardous chemical at the facility (40 CFR §370.42(i)(8)(i)). A facility is reporting forklift batteries on their annual Tier II Inventory Form. How should the facility list the storage location of the hazardous chemicals in the batteries since the forklifts are mobile and not always in the same location?
If it is not possible to list a specific location, a facility may list the storage location of a hazardous chemical as a building (e.g. warehouse, storage room, loading dock, etc.). If the forklifts are present in more than one building over the course of the reporting year, each location should be listed separately on the inventory form.