On February 5, 2015 3:58 pm
By: Kristie Kubovic, Director of Communications, Shale Media Group
Edited By: Mindy Gattner, Editor, Shale Media Group
The deadline for Tier II reporting is quickly approaching. Under the Emergency Planning and Community Right-to-Know Act (EPCRA), which pertains to reporting requirements for hazardous chemical storage, facilities must maintain a list of chemicals, called a material safety data sheet (MSDS), for any hazardous chemical used or stored in the workplace. An inventory of chemicals and these MSDSs must be submitted to their State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC), and local fire department by March 1 of each year. This information must also be available to the public. Many states, such as Oklahoma, take these reports and make them available for public access online, where viewers can search for chemicals stored near their homes.
EPCRA was created in 1986 to help communities plan for emergencies involving hazardous substances. Basically, both state and federal law requires all shale oil and gas producers to comply and file these reports, whether working in the Barnett, Bakken, or Marcellus Shale plays. Additionally, this actually applies to all industries, not just the shale oil and gas industry. Greg Lorson, CEO, TEEMCO, explained, “Preparing and filing the Tier II report can be a lengthy process. However, the initial filing is more complicated than subsequent years as long as there are no significant changes in operations. The report has to be prepared for each individual tank battery and must include a chemical inventory and a facility drawing. It must also identify local fire departments and emergency planning committees.”
In terms of common issues for a shale oil and gas company providing this information, Lorson says, “The most common problem for a company preparing the report is the fact that it is a non-income producing activity. It has nothing to do with actually producing shale oil and gas. Like preparing taxes, it has to be done, but it’s a pure cost with no return on investment. This is why it’s usually most cost effective to outsource this activity to a company, like TEEMCO, that specializes in this type of work. TEEMCO will prepare and file the Tier II report and is able to provide the service at a cost savings due to the volume of reports it prepares each year.”
TEEMCO (Total Energy and Environmental Management Company) is a professional environmental engineering firm, providing solutions to the shale oil and gas, agriculture, and marine industries. The shale oil and gas industry is where the company began its core market. Since the company’s inception, TEEMCO has helped the shale oil and gas industry, including producers, with ever-changing environmental regulations, allowing for increased production, while serving the environment along with health and safety.
“Filing Tier II’s is not only the law; it’s about protecting the lives of our employees and emergency first responders,” expressed Lorson. Essentially Tier II reporting helps keep the community safe and places a system of checks and balances on any industry storing and using chemicals.
Either a Tier I or Tier II form must be submitted by March 1; however, most states require the Tier II form. Along with the MSDS, Tier II forms require basic facility identification information, employee contact information for both emergencies and non-emergencies, and information about the chemicals, such as the manner of storage and their location at the facility. For more information on each state’s Tier II reporting procedures and requirements, click here. For more on TEEMCO or help with Tier II reporting call 877.341.2304.
Shale Media Group (SMG) is the news, information, and education resource dedicated to the shale oil and gas industries by messaging across video, Internet, publications, events, and radio. For more, check out ShaleMediaGroup.com to access all platforms, including SMG’s latest news delivery system–Shale Energy Business Briefing (SEBB), an ad-free subscription based service, where subscribers receive a real-time, daily email, featuring concise, hard hitting shale news 7 days/week, 365 days/year. To sign up, go to sebb.us. Kristie Kubovic is the Director of Communications at Shale Media Group. Contact her at Kristie@ShaleMediaGroup.com.