Tier II frequently requested information

  1. What is CEOS?
  2. Do I have to enter all of my facility locations through "Associate Facility"?
  3. I'm submitting multiple t2s files. Do I need to "associate a facility" for each of them?
  4. What's the difference between a Preparer and a Responsible Official (RO)?
  5. Can a company have more than one Preparer and more than one Responsible Official (RO)?
  6. Why can't I access the "Print Subscriber Agreement" link?
  7. I'm trying to fill out the Subscriber Agreement/Electronic Signature Agreement and I don't know what to write for Facility FIS ID or Permit #.
  8. Why can’t I find a facility in the dropdown menu when I’m getting ready to submit my Tier II report?
  9. What file types are accepted for Tier II reporting?
  10. Who must report under sections 311/312?
  11. How often do I have to report?
  12. What is a reportable chemical?
  13. What are the hazardous chemical storage reporting requirements (EPCRA sections 311/312)?
  14. How do I find my NAICS code?
  15. What are the regulations?
  16. Who can I contact with questions?
 
CEOS Frequently Requested Information

What is CEOS?
The Colorado Environmental Online System (CEOS) is a gateway for environmental permitting, compliance reports, financing, and more. Beginning this year, Tier II report submissions must occur through CEOS. CEOS can be accessed from any computer with an internet connection. It reflects our effort 
to comply with federal electronic reporting rules and clears the way for single-point Tier II submission. 
 
Do I have to enter all of my different facility locations through "Associate Facility"?
Since all of your distinct facilities will be listed in your .t2s report created in Tier2Submit, you may choose to enter only the main company. Please include the name and address where correspondence is received. If you prefer to list multiple facilities (this may be desired for billing purposes), there is no limit to the number of facilities an RO may create/associate. 

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I'm submitting multiple .t2s files. Do I need to "associate a facility" for each of them?
Yes, however do not "associate a facility" for the different locations of a company that are all listed on just one .t2s file. For example, an oil company with 20 wells that lists all of the wells on one .t2s file only needs to "associate a facility" once.
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What’s the difference between a Preparer and a Responsible Official (RO)?
If you’re preparing a Tier II filing on the behalf of a company, but are not the person who certifies it, select the “Preparer” radio button. Preparer is generally the best option for environmental consultants. Once the RO representing that company has created an account and has been approved by CDPHE, that RO will be able to certify the report you prepare. Important: A Preparer is not able to submit or certify a report – only an authorized RO is able to do so.
 
The Responsible Official (RO) is authorized to certify the Tier II report. Once an account is created for an RO, the RO must be approved before Tier II filings can be authorized. E-verify is now available for immediate approval, or the identity of an RO may also be verified by sending a hand signed (or "wet" signature) hard copy of the Electronic Signature Agreement (ESA) to CDPHE's Division of Environmental Health and Sustainability. 

A Responsible Official can both prepare and submit the report. If you accidentally signed up as a Preparer but need to change your status to RO, email us.
 
Can a company have more than one Preparer and more than one Responsible Official (RO)?
Yes, the RO's will follow the steps to associate Preparers with their facility using the instructions For RO's: Submitting a Tier II Report in CEOS.
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Why can't I access the "Print Subscriber Agreement" link?
The link will not be active until a facility is associated. See steps 5-10 in Creating a Tier II Account in CEOS guide to associate a facility.
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I'm trying to fill out the Subscriber Agreement/Electronic Signature Agreement (ESA) and I don't know what to write for the Facility FIS ID or Permit #.
That's ok - leave those fields blank.
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What file types are accepted for Tier II reporting?
Only validated .t2s files may be uploaded through the process described in the instructions. While other file types may be uploaded as Supporting Documents (like PDFs and JPEGs), a .t2s file must be properly uploaded to complete your Tier II reporting process. Please note that Tier II files uploaded to the “Attachment” tab in the “Basic Information” tab under “My Account” are not accepted.
 
Why can’t I find a facility in the dropdown menu when I’m getting ready to submit my Tier II report?
If you can’t find a facility in the dropdown menu in the Data Entry step of Submitting a Tier II report, it may be because:
  • If you’re a Preparer, the RO hasn’t yet requested that your profile connect with the RO profile. To move forward, you can contact your RO and request that he or she complete Step 4 in the “For ROs: Submitting a Tier II Report in CEOS” guide.
  • If you’re an RO, a facility hasn’t yet been associated. To move forward, you can complete Step 5 in the “Creating a Tier II Account in CEOS” guide.
Tier 2 Frequently Requested Information
 
Who must report under sections 311/312?
If the company is required by OSHA to keep any Safety Data Sheet (SDS, formerly Material Safety Data Sheet, or MSDS) on file for hazardous chemicals stored or used in the workplace, and one or more of the chemicals is stored in quantities equal to or greater than the Threshold Planning Quantity (TPQ) for that chemical, then you must file a Tier II form for every year that any of the chemicals exceed the TPQ.
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How often do I have to Report? 
Unless a new chemical exceeds a TPQ (requiring a Tier II report within 90 days), this is an annual report, due March 1, and covers the activity of the previous calendar year (i.e., calendar year 2017 reporting is due March 1 by 5:00 p.m. MST, 2018).
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What is a reportable chemical?
If the U.S Occupational Safety and Health Administration (OSHA) requires your company to keep a SDSs/MSDSs on file for any chemicals stored or used in the workplace, and the chemical(s) is stored in quantities equal to or greater than the Threshold Planning Quantity (TPQ) for that chemical, then you must report it.

The TPQ for these chemicals is either:

  • 500 pounds or the TPQ listed (whichever is lower) for the 356 chemicals listed under Section 302, also known as Extremely Hazardous Substances (EHS); or
  • 10,000 pounds for any other chemical.

Gasoline Exception: In 1999, EPA excluded gasoline held at most retail gas stations from EPCRA 311/312 reporting for gasoline and/or diesel, if stored in underground tanks. This exemption doesn’t apply to fuel mixtures containing more than 10 percent ethanol.

Motor oil, antifreeze and diesel meet the OSHA definition of a "hazardous chemical."

Section 302 EHSs:
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What are hazardous chemical storage reporting requirements (EPCRA sections 311/312)?
Under OSHA regulations, employers must maintain a Safety Data Sheet (SDS) or a Material Safety Data Sheet (MSDS) for any hazardous chemicals stored or used in the workplace. Approximately 500,000 products have SDSs/MSDSs.

Section 311 requires facilities that have chemicals that require MSDSs, and that store more than the Emergency Planning and Community Right-to-Know Act (EPCRA) Threshold Planning Quantity (TPQ) for any of these chemicals, to submit a list of the chemicals, or copies of their SDSs/MSDSs. The Section 311 requirement is met by submitting a Tier II report for the applicable chemicals within 90 days of exceeding the threshold for that chemical.

Under Section 312, facilities covered by Section 311 must submit the Tier II form annually for all chemicals exceeding the reporting threshold in the previous calendar year. In Colorado, facilities meet this requirement by filing a single submission with the Colorado Department of Public Health and Environment. Tier II data submitted to the state is distributed to the LEPCs and local fire departments.
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How do I find my NAICS code?
Both Tier2Submit and the Tier II Form now ask for the primary North American Industry Classification System (NAICS) code for your facility. For more information on NAICS codes and a NAICS search tool, see the U.S. Census Bureau’s Introduction to NAICS.
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What are the Regulations?