Montgomery/Greene County
LOCAL EMERGENCY RESPONSE COUNCIL

Tier II Reporting

A REMINDER
For SARA Title III Facilities
In Montgomery and Greene Counties

 

To the Facility Compliance contacts:

The Montgomery and Greene Counties Local Emergency Response Council (MGCLERC) reminds you that facility chemical inventory reports for 2017 are due by Wednesday, March 1, 2018.  These reports are vital to the emergency response planning conducted by first responders and the two counties' emergency management agencies.  Because the data is so important, MGCLERC offers the following suggestions to make your filing easier:

1.     Get started early.  You may file your reports any time prior to March 1, 2018.  Don't risk filing late by putting it off until the last week.  All submissions must be postmarked on or before March 1, 2018.

2.     Make sure you need to file.  The filing requirement applies to any facility:

o   Required by the Occupational Safety and Health Administration (OSHA) under its Hazard Communication Standard to prepare or have available a Material Safety Data Sheet (MSDS) for a hazardous chemical; and

o   that had on-site, for any one day in the calendar year 2017, an amount of hazardous chemical as found in the Title III "List of Lists" which can be found here:http://www.epa.gov/sites/production/files/2015-03/documents/list_of_lists.pdf

3.     Please consider filing with Tier II Submit Tier II Submit is a database form for entering all the information required for your SARA Title III reporting - including the Ohio state fields.  Tier II Submit allows you to print your reports and/or export the reports to a CD or flash drive.  The exported report can serve as your SARA Title III reports. MGCLERC prefers electronic submissions.  You can email your exported Tier II Submit files to This e-mail address is being protected from spambots. You need JavaScript enabled to view it. .

o   The 2017 version of this free program can be downloaded for Windows or Macintosh from the U.S. EPA website (http://www2.epa.gov/epcra/tier2-submit-software).  You are welcome to call if you need any assistance accessing the program.

o   The US EPA provides a step by step tutorial on the Tier2 Submit software on their website (https://www.epa.gov/epcra/2016-tier2-submit-tutorial)

o   A MGCLERC representative is available for facilities needing assistance getting started with Tier II Submit.  Call (937) 224-8934 for more information.

4.     If you have used Tier II Submit in past years, remember to download and install the 2017 version for your next filing.  The latest version can be found at http://www2.epa.gov/epcra/tier2-submit-software. Please note the following changes in the 2017 Tier II submit software:

o When importing  your previous year's submission file, most of your data will come in as is, but there are a few exceptions:

o The report year is updated, and the date signed is blanked.

o No hazards will be checked due to the new OSHA Global Harmonizing System changes incorporated this year. Note that in order to submit,you will have to check at least one hazard.

o Other changes:

• Added new physical and health hazard categories (to match the revised safety data sheet options)

• Adjusted validation requirement so that "county" is now required for all facilities

• Adjusted validation requirements so that "type", "pressure", and "temperature" are now required for all storage locations     (even those marked confidential)

• Added import check for older MER files to warn users if there are record ID issues that must be resolved this year

• Added export check to warn uses if the file contains invalid characters that would prevent an XML export file from being generated

• Incorporated 2017 North American Industry Classification (NAICS) codes

• Added "Outside Storage Pile" to the list of storage types

• Updated state-specific fields

• Revised helps

• Made additional minor changes and bug fixes

o Note that the data format used in Tier II is changing:

• The older MER file format used historically by Tier2 Submit is in the process of being replaced by a new XML file format that meets the national Tier II data standard requirements released in October 2016.  To give users additional time to transition to the new format, this year's Tier2 Submit 2017 version will continue to support import and export via both the new XML and the older MER file formats.  (More information about the XML files and the data standard can be found at https://cameo.noaa.gov/epcra_tier2/data_standard/v1/index.html.)

• However, next year, Tier2 Submit 2018 will only support XML files. 

• Several checks have been added to Tier2 Submit this year to alert you to potential issues (such as bad record IDs) that might be present in your Tier II data.  These issues will prevent an XML file from being generated during export.  Your export will still include files in the MER format.  Additionally, if you only have a MER-based export file, you will not be able to import that into Tier2 Submit 2018Therefore, if Tier2 Submit alerts you to potential issues in your Tier II data, it is important for you to to resolve those issues this year and create a valid XML export file.

5.     Remember who gets copies! In addition to filing with MGCLERC,  Email or mail a CD copy of the report the State Emergency Response Commission (SERC) at the Ohio EPA, and a paper copy with a site map to your local Fire Department. 

MGCLERC will accept the information either on a CD/flash drive, a paper copy, or via e-mail using the following information.  Please refer to your local phone book if you are unsure of the fire district for your facility, or call for assistance.  The addresses for SERC and MGCLERC are as follows:

State Emergency Response Commission (SERC)                          
c/o Ohio EPA                                                                  
Lazarus Government Center                                             
50 West Town St., Suite 700
P.O. Box 1049
Columbus, OH 43216-1049
Attn: RTK

This e-mail address is being protected from spambots. You need JavaScript enabled to view it.

MGCLERC
Reibold Building
117 S. Main St., Suite 721
Dayton, OH 45422
Attn: Information Coordinator

This e-mail address is being protected from spambots. You need JavaScript enabled to view it.

6.     Don't forget your SERC filing fee.  Filing fees are due to the SERC no later than March 1, 2018.  There are no filing fees for MGCLERC.  Filing fees should be sent to:

Ohio Environmental Protection Agency
Dept. L-2711
Columbus, OH 43260-2711

Check Payable to: Treasurer, State of Ohio
(please include RevenueID# on check)

7.     Call if you have questions.  Please contact our office at (937) 224-8934 (or by e-mail to This e-mail address is being protected from spambots. You need JavaScript enabled to view it. ) if you need assistance or information about your SARA Title III filing.

The MGCLERC thanks you for your cooperation in this effort.  The information which will be compiled from these reports will provide a valuable tool for emergency responders and planners in Montgomery and Greene Counties.

Sincerely,

Randy Allen
Information Coordinator

Montgomery Greene County Local Emergency Response Council

REIBOLD BUILDING    •    117 SOUTH MAIN STREET, SUITE 721    •    DAYTON, OHIO 45422   •    937.224.8934