Do railroads and truckers have to submit Tier IIs?
An entity must meet the definition of “facility” found at 40 CFR 370 in order to be subject to the 312 (Tier II) requirements. Hint: think of “fixed facilities” being subject to Tier II reporting rather than chemicals that are in “transportation.” If a facility uses a railcar of a hazardous chemical for chemical storage at their site, then the facility would definitely have to report this chemical on their Tier II form.
