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Fulfilling original signature requirement for EPCRA Tier II when submitting electronically

Pursuant to EPCRA section 312, facilities must submit Tier II inventory information by March 1st every year.  The owner or operator or the officially designated representative of the owner or operator must submit a certification statement containing an original signature that all information included in the submission is true, accurate, and complete (40 CFR 370.42).  If a facility is reporting electronically, e.g., by using Tier2 Submit, how can they fulfill this original signature requirement?

When reporting Tier II information electronically, the original signature requirement may be met by electronic certification according to requirements established by the state. Facilities that submit their Tier II forms online do not need to also submit a certification statement on paper unless the state and local agencies require it. EPA encourages facility owners and operators to contact their state and local agencies for the reporting requirements in each state.

EPA recognizes that there may be facilities that do not have the capability to submit Tier II forms electronically. Therefore, EPA encourages states and local agencies to allow these facilities to submit paper copies of their Tier II reports and provide an original “wet” signature on paper.

The most recent version of Tier2 Submit, links to state Tier II reporting requirements and contact information, and Tier I and II forms and instructions are available at the following URL: