EPCRA Tier II and SDS Reporting

Stay Audit-Ready with Expert EPCRA Chemical Inventory Reporting Support

In today’s transparency driven regulatory environment, facilities are required to accurately track, evaluate, and report hazardous chemicals under Emergency Planning and Community Right-to-Know Act (EPCRA) and 40 CFR Part 370. EPCRA and related state programs require annual Tier II and SDS reporting which support local emergency planning and community safety. We provide reporting facilities with end-to-end consulting support to confirm reporting applicability, apply exemptions, evaluate mixture rules, reconcile SDS lists, navigate online reporting portals and comply with applicable local/state requirements.

Service Specifics

Our EPCRA Tier II and SDS Reporting Services

See how our chemical inventory reporting services help facilities streamline EPCRA compliance, maintain accurate records, and stay inspection-ready.

We compile chemical inventories, review SDS hazard classifications, screen for extremely hazardous substances, and verify quantities against federal and state Tier II reporting thresholds.

We prepare and quality check SDS and Tier II submissions to ensure they are accurate, complete, and compliant with all federal, state, and local reporting requirements.

Our team audits EPCRA reporting programs to verify requirements are met, pinpoint gaps, and recommend fixes that strengthen compliance and reduce regulatory risk.

Our experts are capable of drafting and updated Safety Data Sheets (SDS) to ensure accurate chemical information and comply with applicable reporting obligations.

We develop usable site maps that clearly identify chemical storage areas and other map elements that comply with applicable EPCRA Tier II reporting requirements.

We help manage the cross-media impacts of chemical changes by coordinating requirements across RMP, PSM, CFATS, TRI, Air, TSCA, SWPPP, RCRA, SPCC, PFAS, and related programs.

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EPCRA Tier II and SDS Reporting FAQs

The Emergency Planning and Community Right to Know Act (EPCRA) requires facilities to report hazardous chemicals stored on site that require a Safety Data Sheet (SDS) under OSHA Hazard Communication Standard (HazCom). Chemical inventory reporting, also called Tier II reporting, involves keeping SDS current and submitting annual Tier II inventory reports that document the chemicals present, their hazards, maximum and average quantities, and storage locations, so state and local agencies can support emergency planning and community safety.

Any facility that is required to maintain Safety Data Sheets under OSHA’s HazCom may be subject to EPCRA chemical inventory reporting if it has hazardous chemicals on site above the applicable thresholds. Because OSHA HazCom covers a very large universe of chemicals and products, most commercial, industrial, and manufacturing facilities should evaluate their inventories each year to confirm whether Tier II reporting applies.

SDS reporting under EPCRA Section 311 focuses on providing hazard information, typically through submitting SDS or a list of hazardous chemicals to the SERC, LEPC, and local fire department when a facility first becomes subject to reporting or when new chemicals or changes to existing chemicals trigger an update. Tier II reporting under EPCRA Section 312 is an annual chemical inventory submission that lists the hazardous chemicals on site above thresholds and summarizes their hazards, quantities, and storage locations.

Failure to submit required SDS, Tier II, or emergency planning reports can lead to enforcement actions, including significant civil penalties that may accrue on a per day, per violation basis. Noncompliance can also undermine coordination with emergency responders by limiting access to accurate hazard, quantity, and location information, which can increase risks to workers, responders, and the surrounding community during a release or incident.

Annual Tier II reports are due by March 1 of each year in most states. Facilities must also update SDS submissions within three months of becoming subject to OSHA requirements, if new hazards are identified, or if chemical compositions change. Emergency planning notifications must be submitted within 60 days of receiving or producing extremely hazardous substances (EHS) at or above threshold planning quantities.

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