Environmental Reporting: EPCRA Tier II Reporting for Combustible Dust

The following is the bottom line on methods for reporting combustible dust… It is an excerpt from a longer article published AFIA on 1/15/19
and is used with permission…

“EPA and industry agree on the following approach for combustible
dust reporting:

The EPA agrees that there are two simple, reasonable options to
complete the Tier II form for combustible dust, which ensures
emergency planners have the relevant information they need
about potential combustible concerns at a feed or grain operation.
Depending on the nature or size of your feed or grain operation:

Reporting Option #1 – If combustible dust is likely present at any
level below the 10,000-pound threshold. If a facility has a reasonable
basis to conclude that it has some volume of combustible dust,
but it is below the 10,000-pound threshold, then a facility should:

(1) check the “combustible dust” box in the “physical hazards” column; and
(2) check the “below reporting thresholds” box in the last column
(the “additional reporting information” column) of the Tier II form.

Reporting option #1 is likely most appropriate for most facilities.
EPA has concluded that there is no obligation for a facility to
provide any further information if the “below reporting
thresholds” is checked.

Reporting Option #2 – If combustible dust is likely above the
10,000-pound threshold If a facility has a reasonable basis to
estimate that it may have combustible dust above the 10,000
-pound threshold, then it should:

(1) check the box in the “physical hazards” column;
(2) complete the “inventory” column using an estimation
method or calculations based on the facility’s best
professional judgment.

This option may be more applicable for those facilities that
collect and store combustible dust in a bin or container.

Reminder: Certain local or state jurisdictions may require additional

While the EPA agrees with industry on the two options for reporting
above, facilities may be subject to additional local or state Tier
II reporting requirements for combustible dust. You may need
to check your county or state requirements to determine
whether this may be the case and complete your Tier II
report accordingly.”