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EPCRA Tier II Reporting for Construction: Do You Need to File?

By HazComFast Safety Team · 2026-03-09 · 8 min read

EPCRATier IIChemical ReportingConstructionEPACompliance2026

What Is EPCRA Tier II?

The Emergency Planning and Community Right-to-Know Act (EPCRA) requires facilities that store hazardous chemicals above certain thresholds to report their chemical inventory annually. This report — the Tier II form — goes to:

1. Your State Emergency Response Commission (SERC)

2. Your Local Emergency Planning Committee (LEPC)

3. Your local fire department

The purpose: ensuring first responders know what chemicals are on your site before an emergency.

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Does My Construction Site Need to File?

The 10,000-Pound Rule

If your site stores 10,000 lbs or more of any hazardous chemical (any chemical with an SDS) at any point during the calendar year, you must file.

Common Construction Chemicals That Count

| Chemical | Where It Adds Up |

|----------|-----------------|

| Diesel fuel | Equipment fueling, generators (1 gallon ≈ 7 lbs) |

| Gasoline | Vehicles, small equipment |

| Propane | Heaters, forklifts |

| Concrete admixtures | Large pours |

| Paints & coatings | Interior/exterior finishing |

| Adhesives & sealants | Flooring, roofing |

| Acetylene/oxygen cylinders | Welding operations |

Quick Math: Diesel Example

A 1,500-gallon diesel tank on a construction site = approximately 10,500 lbs. That single tank triggers Tier II reporting.

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Extremely Hazardous Substances (EHS)

For the 366 Extremely Hazardous Substances listed under EPCRA §302, the threshold is much lower: 500 lbs or the Threshold Planning Quantity (TPQ), whichever is lower.

Construction-relevant EHS chemicals include:

  • Chlorine (TPQ: 100 lbs)
  • Ammonia (TPQ: 500 lbs)
  • Sulfuric acid (TPQ: 1,000 lbs)
  • Hydrochloric acid (TPQ: 500 lbs)
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    What Goes in the Tier II Report?

    For each chemical above the threshold:

    1. Chemical identity — product name, CAS number

    2. Physical and health hazards — fire, reactive, acute, chronic

    3. Maximum amount present at any time during


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