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Tier II Reporting

 
Tier II Reporting Changes
Beginning January 10, 2012, Philadelphia Tier II facilities will only submit Tier II reports to the Pennsylvania Bureau of PENNSAFE’s PATTS website. This is the state Tier II reporting website that companies have been using when filing Tier II reports with the state and the website address is: http://www.lipatts.state.pa.us/submit. The local Philadelphia LEPC reporting website has been deactivated as the LEPC will receive Tier II data from the PATTS website for Tier II facilities. If you have questions about Tier II reporting or you have trouble with your PATTS account, please contact the Pennsylvania Bureau of PENNSAFE at 1-888-SAFE-422.  

 
Billing
Tier II facilities will continue to receive a bill from both the state and the LEPC. The current LEPC Tier II fees are as follows: 
- $75.00/chemical
- $100.00 flat emergency planning fee for facilities storing Extremely Hazardous Substances (EHS) above the EPA’s Threshold Planning Quantity (TPQ)
Questions about local billing should be directed to the LEPC: 215-686-1141 or LEPC@phila.gov


Off-Site Emergency Response Plans
Facilities storing EHS above TPQ will need to complete an Off-Site Emergency Response Plan that the LEPC has developed. When billed, qualifying Tier II facilities will receive the plan template and will be instructed to complete certain sections of the plan with facility-specific information (e.g., Facility emergency contacts, equipment, communications systems, etc.). After completing this information, facilities will send the plan back to the LEPC at the following e-mail address: LEPC@phila.gov. The LEPC will complete the remaining plan and approve it. Once the plan has been approved by the LEPC, facilities will be sent the completed, approved plan and will be asked to upload the plan to the PATTS website.

For more information about Tier II reporting, please click here.

 
What is Tier II reporting?
Under the federal Emergency Planning and Community Right to Know Act (EPCRA), facilities using, storing or manufacturing more than a certain amount of hazardous chemicals on-site at any time during the 2011 calendar year are required to submit reports on their chemical inventories and pay fees to the state and local authorities. Please use the reference table below to assist in determing whether or not to file a Tier II report.

 
Tier II Reporting Thresholds
Extremely Hazardous Substances (EHS), as defined by the EPA*: Greater than 500 pounds (227 kg) or the Threshold Planning Quantity, whichever is less. 
Any other hazardous chemical for which OSHA requires employers to maintain a MSDS sheet**: 10,000 pounds (4,540 kg) or more.
*The List of Extremely Hazardous Substances and their Threshold Planning Quantities is found within U.S. Title 40, Volume 27, Part 355, Appendix A.

**OSHA's definition of a hazardous chemical is found within U.S. Title 29, Volume 6, Part 1910, Subpart 1910.1200.


Both of the Federal standards described above can be viewed online at:
http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&tpl=%2Findex.tpl


Where must I submit Tier II reports?
 
Required facilities must file Tier II reports with the following agency:
  • The Pennsylvania Department of Labor & Industry, Bureau of PENNSAFE.  Additional information on submitting Tier II reports to PENNSAFE may be found by calling 1-888-SAFE-422.  


How do I submit my Tier II report?

As of July 1, 2011 the local Tier II online reporting database will no longer be functional. For the 2012 reporting season, companies will submit Tier II forms electronically to the state's PATTS system and will no longer need to submit them electronically to the Philadelphia Local Emergency Planning Committee. Please check back frequently for updates regarding the new reporting process. For more information, please contact the Philadelphia Local Emergency Planning Committee at 215-686-1141.

 
How do I pay my Tier II fees?  
Once you have submitted and certified your Tier II report with the state’s PATTS system, an invoice will be sent to the e-mail address you provided in the system. Remit your invoice with a check or money order made payable to 'City of Philadelphia' to the following address:

Tier II Manager
Office of Emergency Management
240 Spring Garden Street, Lower Level
Philadelphia, PA 19123



Further Information and Assistance 
You may obtain additional information and assistance in preparing and submitting Tier II reports by contacting the Philadelphia Local Emergency Planning Committee at 215-686-1141.

Department of Homeland Security Critical Infrastructure: Chemical Security 

 

Although not a LEPC function, please note that Chemical Facility Anti-Terrorism reporting is also required.  The Department of Homeland Security has issued Chemical Facility Anti-Terrorism Standards for any facility that manufactures, uses, stores, or distributes certain chemicals above a specified quantity.
 
For additional information visit the Department of Homeland Security's Critical Infrastructure: Chemical Security webpage http://www.dhs.gov/xprevprot/programs/gc_1169501486179.shtm

 
 
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