Environmental Management

Tier II Reporting Requirements

United States Postal Service® (USPS®) policy requires USPS sites that store quantities of hazardous chemicals exceeding reporting thresholds to comply with Emergency Planning and Community Right-to-Know Act (EPCRA) Tier II reporting requirements. The Tier II form contains information on the quantities, hazards, and locations of onsite hazardous materials storage.

The EPCRA Tier II form must be completed annually by March 1 (for reporting year 2022) to ensure state and local emergency response organizations are notified about any potential onsite hazards.

Commonly reported chemicals and thresholds applicable to USPS sites include:

n Lead-acid and gel cell batteries. The 500-pound threshold for sulfuric acid is met by onsite storage of more than six tow motor batteries or more than two forklift batteries, or a combination of these batteries. Estimate the percent weight of sulfuric acid in the battery by multiplying the battery weight by 18 percent.

n Gasoline, diesel, or heating fuel. The 10,000-pound threshold is equivalent to 1,639 gallons of gasoline (6.1 pounds/gallon) or 1,351 gallons of diesel/heating fuel (7.4 pounds/gallon).

n Ice melt and anti-skid products. Rock salt, calcium magnesium acetate, calcium chloride, and sand have a 10,000-pound threshold. The threshold applies whether the materials are stored in one bulk location or dispersed in bags or on pallets throughout the site.

n Propane. The 10,000-pound threshold is equivalent to 2,380 gallons of propane as liquified petroleum gas (LPG) using the weight of 4.2 pounds per gallon.

Note: Due to COVID-19, many USPS facilities stored bulk quantities of hazardous materials associated with cleaning and disinfection during 2022. While it is unlikely these chemicals were stored in quantities that require Tier II reporting, review each product’s safety data sheet to confirm ingredients and the associated reporting thresholds. In most cases, the federal reporting threshold is 10,000 pounds. For USPS-approved, alcohol-based hand sanitizers, 10,000 pounds is equivalent to storing more than twenty 55-gallon drums of hand sanitizer onsite at one time.

Reporting requirements apply to any location that stores threshold quantities of EPCRA-regulated hazardous and toxic chemicals. In most cases, the federal reporting threshold is 10,000 pounds. Each state has different Tier II submission procedures. States may require:

n Hard copy submission of the Tier II form;

n Electronic reporting through the EPA Tier2 Submit software program; or

n Reporting through their own state-specific software programs or websites.

For more information, review the Environmental Affairs Tier II Reporting website at blue.usps.gov/sustainability/environmental/tier-ii-reporting.htm or consult your designated environmental contact at blue.usps.gov/sustainability/contact.htm.