USPS: Federal Reporting Requirements on Hazardous and Toxic Chemicals

Hazardous-Chemicals-CautionPostal Service™ policy requires all USPS® facilities to comply with reporting requirements of the Emergency Planning and Community Right-to-Know Act (EPCRA), if applicable. Postal sites that store certain quantities of haz­ardous and toxic chemicals must complete and submit the EPCRA Tier II Form by March 1, every year.

Reporting requirements apply to any location that stores threshold quantities of EPCRA-regulated hazardous and toxic chemicals. Regulated chemicals used by the Postal Service include sulfuric acid in lead-acid batteries, gaso­line, diesel, heating oil, and ice melt/anti-skid products, as discussed in greater detail below.

Applicability

Commonly reported chemicals and thresholds applica­ble to USPS facilities include:

  • Lead-acid batteries: The 500 pound threshold for sulfuric acid can be met by having more than six (6) tow motor batteries or more than two (2) forklift bat­teries, or a combination of these batteries onsite. The percent weight of sulfuric acid in the battery can be estimated by multiplying the battery weight by 18 percent.
  • Gasoline, diesel, or heating fuel: The 10,000 pound threshold is equivalent to 1,433 gallons of gasoline or 1,223 gallons of diesel/heating fuel.
  • Ice melt/anti-skid products: Rock salt, calcium magnesium acetate, and sand have a 10,000 pound threshold. The threshold applies whether or not the materials are stored in one bulk location or dispersed on bags or pallets throughout the site.

Reporting Process

As applicable, USPS Installation Heads should submit the emergency and hazardous chemical inventory report­ing form, known as the Tier II Form, annually by March 1 to the following organizations:

  • The State Emergency Response Commission (SERC);
  • The Local Emergency Planning Committee (LEPC); and
  • The local Fire Department that would respond to an emergency at your facility.

States may require reporting through the submittal of the hard-copy Tier II Form, electronic reporting through EPA’s “Tier2 Submit” software program, or through their own state-specific software programs or websites. Each state’s individual reporting requirements, procedures, and forms can be accessed at http://www2.epa.gov/epcra-tier-i-and-tier-ii-reporting.

For states that recommend EPA’s Tier2 Submit 2014 software, postal facilities should be able to utilize eAccess to request download of the Tier2 Submit 2014 software for use in electronic reporting. If other state electronic report­ing software or website applications are not accessible or authorized on your USPS ACE computer system, you should report by hard copy communications using the paper Tier II Form.

Note: USPS facilities are not required to pay any fees associated with reporting (including electronic reporting user and registration fees).

Additional detailed reporting instructions are available through the appropriate Regional Manager of Environmen­tal Compliance and Sustainability and on the Sustainability website at http://blue.usps.gov/sustainability/environmen­tal/spills_and_regulatory_reporting.htm. If you have ques­tions regarding your need to report under EPCRA, contact your Regional Manager. For Northeast, Eastern, Capital Metro Areas, and Headquarters-related facilities, contact Nicholas DeCarlo at nicholas.decarlo@usps.gov. For ques­tions related to EPCRA reporting in the Great Lakes, West­ern, Southern, and Pacific Areas, contact Judy Wingo-Stalinger at judy.wingo-stalinger@usps.gov.

— Environmental Compliance and Risk Management,
Office of Sustainability, 2-5-15

via Sustainability.

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