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EPCRA Reports Due by March 1, 2018 – Updated


Tier 2 Emergency and Hazardous Chemical Inventory reporting is approaching. The Emergency Planning and Community Right to Know Act (EPCRA) of 1986 was implemented to help communities plan for emergencies involving hazardous substances. EPCRA requires hazardous chemical emergency planning by federal, state and local governments, Indian tribes, and industry. It also requires industry to report on the storage, use, and releases of hazardous chemicals to federal, state, and local governments. The primary group of PMCI members impacted by the reporting requirements will be bulk plant operators, but marinas and fleet fueling facilities may also fall within the scope of the regulation. Most C-stores are exempted from the reporting requirements unless storing more than 75,000 gallons of gasoline or 100,000 gallons of diesel fuel in underground storage tanks.

The following classification numbers will be requested from facilities:

CAS Numbers:

Gasoline- CAS 8006-61-9

Diesel Fuel – CAS 68334-30-5

Kerosene – CAS 8008-20-6

Fuel Oil – CAS 68334-30-5

Aviation Gasoline, Jet A, JP 8 – CAS Mixture

NAICS Code (SIC no longer adequate):

Petroleum Bulk Plants: NAICS 424710

Heating Oil Dealers: NAICS 454311

Retail Gasoline Stations with Convenience Stores: NAICS 447110

Retail Gasoline Stations without Convenience Stores: NAICS 447190

New Information Required on EPCRA Forms:

New EPCRA forms now require information on the physical hazards and health hazards of each product stored on site meeting the minimum reporting threshold (10,000 lbs). This information must be obtained from Safety Data Sheets (SDS) provided by your supplier. Suppliers are required to provide a copy of the most recent SDS for product sold to downstream petroleum marketers. Suppliers often have a copy of their SDS on their website.

Physical and health hazard categories appear as two separate columns on the new Tier 2 Form. Under each column, a series of hazards are listed next to check off boxes. For physical hazards check the boxes marked explosive and flammable. For health hazards check the following boxes:

  • Skin corrosion or irritation
  • Serious eye damage or irritation
  • Respiratory or skin sensitization
  • Carcinogenicity
  • Reproduction toxicity
  • Aspiration hazard


Dun and Bradstreet Number Locator:

My Dun and Bradstreet Number

Toxic Release Inventory (TRI) and Risk Management Program (RMP):

Tier 2 forms now ask whether the facility is subject to emergency planning under Section 302 of EPCRA (TRI) or the chemical accident prevention requirements under 112r of the Clean Air Act (RMP). Typically, small petroleum bulk plant operators located downstream from a terminal rack are not subject to TRI or RMP.

State Submission:

Click here to visit the Iowa DNR Tier II reporting site which includes registration and reporting information along with current contact and Tier II submittal information by county. Reporting is due annually by March 1. For help with the DNR website please contact Elonda Bacon at 515.725.0302 or iowa.epcra@dnr.iowa.gov.

State Tanks and Equipment Federal

RINAlliance EMC Insurance Seneca Companies LMC Insurance & Risk Management Altria PMMIC Insurance Renewable Energy Group Unified Contracting Services Cylinder Express Sinclair Solar Transport Growmark Energy Farner-Bocken Company a Division of Core-Mark Land Mark Products Federated Insurance Iowa Lottery Flint Hills Heartland Payment Systems McGowen, Hurst, Clark & Smith PC Community Oil Company Wellmark Phillips 66 Molo Petroleum Valero Shell Central Bank Acterra Group Keck Energy
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