Is a Dun & Bradstreet number required for EPCRA Tier II?

Pursuant to EPCRA Section 312, facilities must submit Tier II inventory information by March 1st every year. Is the Dun & Bradstreet number a required data element for Tier II inventory reporting?

The Dun & Bradstreet number (also referred to as a D&B number or D-U-N-S number) is a required data element for Tier II inventory reporting (40 CFR §370.42(i)). This field has been required since the October 15, 1987, final rule (52 FR 38344). If a facility has previously been assigned a Dun & Bradstreet number, the financial officer of the facility should be able to provide it. If the financial officer does not have this information, the facility should contact the state or regional office of Dun & Bradstreet to obtain the facility’s number or determine if the facility is eligible to have one assigned. Facilities can also contact Dun & Bradstreet at 800-234-3867 or https://www.dnb.com to obtain the facility’s number, or to create a new number if the facility does not currently have a number.

To enter a Dun & Bradstreet number in Tier2 Submit, the facility should select Dun & Bradstreet from the ID Type drop down list and then enter the primary Dun & Bradstreet number in the ID field for the business operating the facility. If the facility contacts Dun & Bradstreet and determines the facility is not eligible to receive a number, the facility must add the Dun & Bradstreet as an ID Type in Tier2 Submit but may enter N/A in the ID field. On the Tier II form, a facility that has a Dun & Bradstreet number should enter it in the appropriate field, while a facility not eligible to receive one may enter N/A in that field.