THE CASE FOR VOLUNTARY REPORTING Having set the stage with what Tier II reporting entails, let’s discuss the broader implications for auto dealers, especially when their chemical quantities fall below these regulatory thresholds. Should they simply operate under the radar, or is there value in adopting a more proactive approach to environmental reporting? This article aims to explore these questions, highlighting the reasons auto dealers — and indeed, facilities in other sectors — might consider voluntarily submitting Tier II reports even if not strictly mandated. 1. Preparing for the Unexpected: Accidents Aren’t Always Predictable. No facility can predict every accident. While comprehensive safety measures can be in place, the unexpected can still occur. For instance, lithium-ion electric car batteries might be below reporting thresholds, but in the event of a fire, their presence becomes a crucial piece of REQUIRED VS. VOLUNTARY TIER II ENVIRONMENTAL REPORTING FOR AUTO DEALERS BY CHRIS CLEVELAND CEO AND CO-FOUNDER, COMPLYAUTO UNDERSTANDING TIER II REPORTING — WHEN IT’S REQUIRED At its core, Tier II reporting is an essential component of the Emergency Planning and Community Right-to-Know Act (EPCRA). It mandates that facilities provide the Environmental Protection Agency (EPA) and state and local authorities with details about the storage, use and release of specific hazardous chemicals. These chemicals, when present in amounts above certain thresholds, need to be reported to the EPA or applicable state agency and/or fire department. The thresholds can vary depending on the chemical and its hazard classification, but they are designed to ensure that local communities and first responders have information about potential hazards in their vicinity. Furthermore, reporting requirements can have slight variations from one state to another, making it critical for businesses to be familiar with their state’s specific mandates. Auto dealers often come under the purview of Tier II reporting due to the nature of chemicals they store and use. These include, but are not limited to, motor oils, fuels, brake cleaner, anti-freeze, lead-acid batteries (e.g., used car batteries, as well as those present in industrial equipment, like forklifts) and electric car batteries. To illustrate, three common examples that trigger reporting requirements are listed below. Given the potential environmental, health and safety impacts of these substances, understanding and complying with Tier II requirements is crucial for dealerships. Hazardous Material EPA Reporting Threshold Common Dealer Use Case Example Calculations Based on Average Weight Lead-Acid Batteries (Sulfuric Acid) 500 pounds Used lead-acid car batteries Forklift batteries 12 used car batteries x 45 lbs. = 540 lbs. 1 forklift battery = 2,000 lbs. Gasoline 10,000 pounds New/waste gasoline 1,612 gal of new/waste gasoline = 10,000 lbs. Lithium-Ion Batteries (lithium nickel/cobalt-oxide) 10,000 pounds Electric vehicle batteries 10 new and/or used lithium ion batteries x 1,000 lbs. = 10,000 lbs. THE GENERATOR 24
RkJQdWJsaXNoZXIy MTg3NDExNQ==