Hazardous Chemical Inventory Reporting | US EPA (2024)

Table of Contents

EPCRA Sections 311-312 What facilities are covered? What is a hazardous chemical? What are facilities required to do? How do I submit a Tier I or Tier II Inventory Report? Where can I find more information on these requirements? FAQs References

EPCRA Sections 311-312

For any hazardous chemical used or stored in the workplace, facilities must maintain a safety data sheet (SDS) (formerly known as material safety data sheet, MSDS). Facilities must submit the safety data sheet (SDS) or a list of hazardous chemicals to their State or Tribal Emergency Response Commission (SERC or TERC), Local or Tribal Emergency Planning Committee (LEPC or TEPC), and local fire department.

Facilities must also submit an annual inventory of these chemicals by March 1 of each year to their State or Tribal Emergency Response Commission (SERC or TERC), Local or Tribal Emergency Planning Committee (LEPC or TEPC), and local fire department. The information submitted by facilities must be made available to the public.

What facilities are covered?

Any facility that is required to maintain SDSs under the Occupational Safety and Health Administration (OSHA) regulations for hazardous chemicals stored or used in the workplace.

Facilities with chemicals in quantities that equal or exceed the following thresholds must report:

For Extremely Hazardous Substances (EHSs) (40 CFR part 355 Appendix A and AppendixB), either 500 pounds or the Threshold Planning Quantity (TPQ), whichever is lower.

For gasoline (all grades combined) at a retail gas station, the threshold level is 75,000 gallons (or approximately 283,900 liters), if the tank(s) was stored entirely underground and was in compliance at all times during the preceding calendar year with all applicable Underground Storage Tank (UST) requirements at 40 CFR part 280 or requirements of the State UST program approved by the Agency under 40 CFR part 281.

For diesel fuel (all grades combined) at a retail gas station, the threshold level is 100,000 gallons (or approximately 378,500 liters), if the tank(s) was stored entirely underground and the tank(s) was in compliance at all times during the preceding calendar year with all applicableUST requirements at 40 CFR part 280 or requirements of the State UST program approved by the Agency under 40 CFR part 281.

For all other hazardous chemicals: 10,000 pounds.

What is a hazardous chemical?

Hazardous chemicals are substances for which a facility must maintain a SDS under the OSHA Hazard Communication Standard, which lists the criteria used to identify a hazardous chemical. SDSs are detailed information sheets that provide data on health hazards and physical hazards of chemicals along with associated protective measures. Over 500,000 products have SDSs which are normally obtained from the chemical manufacturer.

What are facilities required to do?

Under Section 311 of the Emergency Planning and Community Right-to-Know Act (EPCRA), facilities must submit the SDSsof hazardous chemicals present on-site at or above the reporting threshold to their State or Tribal Emergency Response Commission (SERC or TERC), Local or Tribal Emergency Planning Committee (LEPC or TEPC), and local fire department. Facilities may choose to submit a list of the hazardous chemicals grouped into hazard categories instead. This is a one-time submittal. New facilities have three months after becoming subject to the OSHA regulations to submit their SDSs or the list of the hazardous chemicals to their State or Tribal Emergency Response Commission (SERC or TERC), Local or Tribal Emergency Planning Committee (LEPC or TEPC), and the fire department.

Facilities that need to submit SDSs or the list of hazardous chemicals under Section 311, also need to submit an annual inventory report for the same chemicals (EPCRA Section 312). This inventory report must be submitted to the State or Tribal Emergency Response Commission (SERC or TERC), Local or Tribal Emergency Planning Committee (LEPC or TEPC), and the local fire department by March 1 of each year.

Please check with your state, tribe, or territory for any additional reporting requirements.

How do I submit a Tier I or Tier II Inventory Report?

Facilities covered by these requirements must submit an emergency and hazardous chemical inventory form to their State or Tribal Emergency Response Commission (SERC or TERC), Local or Tribal Emergency Planning Committee (LEPC or TEPC), and the local fire department annually. Facilities provide either a Tier I or Tier II form. Most States require the Tier II form. Tier II forms require basic facility identification information, employee contact information for both emergencies and non-emergencies, information about chemicals stored or used at the facility, and additional data elements which would be useful to local planners and responders.

The following is a list of some of the information required on the inventory form:

The chemical name or the common name as indicated on the SDS
An estimate of the maximum amount of the chemical present at any time during the preceding calendar year and the average daily amount
A brief description of the manner of storage of the chemical
The location of the chemical at the facility
An indication of whether the owner of the facility elects to withhold location information from disclosure to the public

Tier I Forms and Instructions

Tier II Forms and Instructions

Tier II Reporting Requirements by State and Tier2 Submit Software

Where can I find more information on these requirements?

For more information, see 40 CFR part 370and EPCRAAmendmentsand EPCRA Guidance Documents and Fact Sheets.

Hazardous Chemical Inventory Reporting | US EPA (2024)

FAQs

How often are hazardous chemical inventories required to be reported to safety management? ›

EPCRA Section 312 requires facilities covered by Section 311 to submit an emergency and hazardous chemical inventory form (“Tier I” or “Tier II”) to the SERC or TERC, LEPC or TEPC, and the local fire department, annually, by March 1.

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What must be listed on hazardous chemical inventory? ›

The following is a list of some of the information required on the inventory form:

The chemical name or the common name as indicated on the SDS.
An estimate of the maximum amount of the chemical present at any time during the preceding calendar year and the average daily amount.

More items...

Nov 14, 2023

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What must your company list in the hazardous chemical inventory? ›

First, we will clarify your responsibility in making an inventory of chemicals in the work place: employers must list the names of all hazardous chemicals used in the workplace by using the identity that is referenced on the material safety data sheet (MSDS).

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How often is fiu required to submit the emergency and hazardous chemical inventory tier ii form group of answer choices? ›

Owners or operators of facilities that have hazardous chemicals present at the facility at any one time in quantities equal to or greater than set threshold levels must submit either Tier I or Tier II form by March 1 annually regarding information on hazardous chemicals present at the facility in the previous calendar ...

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How often should a chemical inventory be performed? ›

How often should an inventory be conducted? Chemical inventories should be conducted on at least a yearly basis. Personnel should be looking at the physical condition of primary and secondary containers.

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What are your employer's responsibilities regarding the hazardous chemical inventory? ›

Employers must maintain copies of SDSs for all hazardous chemicals present in their workplaces. If you do not receive an SDS from your supplier automatically, you must request one. You also must ensure that SDSs are readily accessible to workers when they are in their work areas during their work shifts.

What is not required in a chemical inventory? ›

Items that should not be added to the chemical inventory (but not limited to) are: Biological culture media, agar, serum proteins, albumin, toxins. Antibiotics, antibodies. Cell Culture items – such as Trypsin and Fetal Bovine Serum.

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Which of the following must be included in the chemical inventory? ›

Only hazardous chemicals, those possessing qualities of a physical or health hazard as defined by OSHA, are required to be included on the chemical inventory. This includes all liquids, solids, and compressed or liquefied gases.

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What are four items that must be contained on a chemical information list? ›

Labels for a hazardous chemical must contain:

Name, Address and Telephone Number • Product Identifier • Signal Word • Hazard Statement(s) • Precautionary Statement(s) • Pictogram(s) Page 3 3 above, the label could state, “Do not breathe vapors or spray. Get medical attention if you feel unwell.

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What chemicals need to be inventoried on the chemical inventory log? ›

Chemicals that must be included within your inventory:

of Transportation, 49 CFR 172, Subpart B. Extremely Hazardous Substances as defined by 40 CFR 355, Subpart D. Flammable or combustible liquid, solid, or gas. Carcinogenic, mutagenic, or teratogenic materials.

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Who is responsible for making and updating a chemical inventory list? ›

In response to your inquiry, the employer is responsible for conducting the hazardous chemical inventory and developing the list of all hazardous chemicals in the workplace by using the identity that is referenced on the MSDS and the container label.

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What is the difference between tier 1 and tier 2 reporting? ›

SARA Title III does allow for the use of a Tier I, which requires information to be aggregated and reported by hazard category. The Tier II form requires information for each individual chemical and also information concerning specific location and storage of the reported chemical.

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What triggers Tier II reporting? ›

If you store hazardous chemicals in quantities equal to or greater than the reporting threshold for that chemical you must submit a Tier II Report.

What is US EPA tier 2? ›

The Tier 2 standards apply to all vehicles that were covered by Tier 1 and, additionally, to “medium-duty passenger vehicles” (MDPV). The MDPV is a new class of vehicles that are rated between 8,500 and 10,000 lbs GVWR and are used for personal transportation.

How often must the Hazardous Substance List be updated? ›

Chemical manufacturers, importers, distributors, or employers who become newly aware of any significant information regarding the hazards of a chemical, or ways to protect against the hazards shall revise SDSs within 3 months. The labels shall be revised within 6 months.