Navigating Tier II Hazardous Chemical Inventory reporting requirements
With the March 1 deadline for all Tier II reports looming, it’s important to review federal and state requirements and ensure your facility’s 2025 Hazardous Chemical Inventory is properly documented.
Under section 312 of the Emergency Planning and Community Right-to-Know Act (EPCRA), facilities that have hazardous chemicals in reportable amounts must submit the Tier II report. These reports inform State Emergency Response Commissions (SERCs), Local Emergency Planning Committees (LEPCs), local fire departments, and the public about the facilities’ chemicals and their associated hazards. The reports help communities prepare an appropriate response in case of an emergency.
Below are some common questions about the Tier II form requirements and submission methods.
How do I know if the chemicals at my facility are hazardous substances?
If, at any time during 2025, your facility was required to prepare or have available a safety data sheet (SDS) for a chemical, according to the Occupational Health and Safety Administration’s (OSHA) Hazard Communication Standard (HCS), then you had hazardous chemicals on-site.
There are some exemptions, so refer to Section 311(e) of EPCRA or 40 CFR 370.13 for a detailed list of chemicals that aren’t applicable.
How do I know if my facility had reportable amounts of hazardous chemicals?
The reporting threshold of chemicals depends on its category. Below is a list of potentially reportable chemicals and their reporting thresholds (equal to or greater than):
- Extremely Hazardous Chemicals (EHS): 500 pounds or the Threshold Planning Quantity (TPQ), whichever is lower. EHSs and their TPQs can be found in 40 CFR 355 Appendices A and B.
- Gasoline in underground storage tanks at retail gas stations: 75,000 gallons.
- Diesel fuel in underground storage tanks at retail gas stations: 100,000 gallons.
- All other hazardous chemicals requiring a safety data sheet (SDS): 10,000 pounds.
Remember: if, during the past calendar year, you had a hazardous chemical in the above quantities at your facility – even for just a day; even if it’s no longer there – you must record it on the Tier II report.
It’s also important to note that some states have lower reporting thresholds, so double-check local regulations.
Mixtures
Perhaps the most tricky part of determining the quantity of hazardous chemicals at your facility is calculating mixtures:
- If you are calculating the total amount of an EHS onsite, you must add together the quantity of that EHS as a component in all mixtures with all other quantities of the pure EHS. If the total is equal to or greater than 500 pounds or the TPQ, whichever is less, you must report it.
- If you are calculating the total amount of a non-EHS hazardous chemical onsite, you must add together the quantity of the chemical as a component in all mixtures with all other quantities of the chemical OR determine the quantity of the mixture present throughout the facility at any one time. If the total quantity of the non-EHS chemical or mixture (depending on which option you choose) is equal to or greater than 10,000 pounds, you must include it in your Tier II report.
When it comes to reporting mixtures in the Tier II report, you have two options:
- Report the entire mixture (total quantity of mixture); or
- Report only the EHS or non-EHS chemical component of the mixture.
Either way, the way in which you calculate and report your mixtures for Tier II must match how you calculate and report mixtures for EPCRA Section 311, Safety Data Sheets (SDS) Reporting.
How do I prepare and submit my Tier II report?
The Environmental Protection Agency (EPA) provides a Tier II form and instructions online. The webpage outlines what you need to include in your report, based on federal regulations. Additionally, the Tier2 Submit Software helps facilities prepare their Hazardous Chemical Inventory form. Note that there have been some changes to the 2025 Tier2 Submit software, including updated state-specific fields and updated Extremely Hazardous Substances lists.
However, you still need to contact your state. Most states, and some local jurisdictions, have their own online Tier II reporting software. Don’t assume that using the federal software program will automatically meet all state and local requirements.
Getting started
With February in full swing, now is the best time to start collecting the information you’ll need to successfully complete your Tier II report:
- Determine which chemicals you need to report. Identify hazardous substances and EHSs, then determine if the quantity onsite on any single day during the reporting year exceeded the threshold. This includes evaluating SDSs to determine components of mixtures.
- Determine which exemptions apply to your facility by checking 40 CFR 370.13.
- Compile all necessary data to complete the Tier II forms, including pure chemical and mixture names and amounts, as well as their corresponding physical or health hazards which can be found in SDSs. You also need to note storage conditions and locations. You can note the location of chemicals either through a description or on a site map.
- Find out if there are any additional requirements in your jurisdiction. Many states have additional requirements for applicability, chemicals, and even report content.
- Determine the method(s) of report submission in your jurisdiction.
Don’t wait – the March 1 deadline will be here soon.
