Our process starts with an inventory of any regulated chemicals manufactured, processed, used, and/or stored at the facility. We can then identify if Section 302 or Emergency Response Plans are triggered, and evaluate if chemicals commonly missed in the inventory are also missing from existing reports. Our consultants prepare hundreds of Tier II and TRI reports annually, accounting for material inventories from the time they arrive on site until the time they leave, whether as a product, waste, a release, or form of energy. For facilities that do not meet the requirement to submit Tier II or TRI, we clearly document the regulatory applicability and chemical threshold determination needed to quickly respond should an agency ask why a report was not submitted.
