Does OSHA require a chemical inventory list?

Yes. 29 CFR 1910.1200(e)(1)(i) requires employers to maintain a list of hazardous chemicals known to be present in the workplace, cross-referenced with SDSs.

How does GHS Rev 7 affect Tier II reporting?

The EPA is aligning its reporting requirements with OSHA's GHS updates. The Physical and Health hazard checkboxes on your Tier II report (due March 1 annually) must reflect Revision 7 classes like Chemicals Under Pressure.

Ultimate Chemical Inventory: OSHA & Tier II Template

The One-List Solution

For safety managers, maintaining separate chemical lists for OSHA compliance and EPA Tier II reporting is a waste of time and a recipe for error. The "Ultimate Chemical Inventory" is a single, master dataset that satisfies the requirements of both the OSHA Hazard Communication Standard (29 CFR 1910.1200) and the EPA's Emergency Planning and Community Right-to-Know Act (EPCRA).

With the recent alignment of EPA Tier II hazard categories to the OSHA GHS physical and health hazards, the friction between these two regulations has been reduced. However, the data capture requirements remain rigorous.

Essential Data Fields for the Template

To build a compliant master inventory, your spreadsheet must capture specific fields that feed into both regulatory reports.

1. Identity & Location

Product Identifier: Must match the SDS exactly (OSHA requirement).
CAS Number: Critical for screening against the EPA's List of Lists for Extremely Hazardous Substances (EHS).
Storage Location: Specificity matters. "Site Layout Zone 4" is better than "Jobsite."

2. Quantities (The Tier II Trigger)

Max Daily Amount (lbs): The highest inventory level reached at any point in the year.
Average Daily Amount (lbs): The weighted average.
Container Type: (e.g., Drum, Tote, Cylinder).
Physical State: (Solid, Liquid, Gas).

3. Hazard Classifications (The New Standard)

You must now map chemicals to the specific OSHA GHS categories rather than the old EPA "Five Hazard Categories" (Fire, Pressure, Reactivity, Immediate, Delayed).

Physical Hazards: Flammable Liquid (Cat 2), Oxidizing Solid (Cat 1), Aerosol (Cat 3).
Health Hazards: Carcinogenicity (Cat 1A), Skin Corrosion (Cat 1B), Specific Target Organ Toxicity.

Reporting Thresholds: When to Report?

For construction sites, the 2026 reporting thresholds are the triggers that turn a simple inventory list into a mandatory federal report:

10,000 lbs: The general threshold for hazardous chemicals (e.g., diesel fuel, bulk cement, drywall).
500 lbs (or TPQ): The threshold for Extremely Hazardous Substances (EHS). If you store Sulfuric Acid (batteries) or Ammonia, the threshold is 500 lbs or the Threshold Planning Quantity (TPQ), whichever is lower.
Gasoline (Retail UST): 75,000 gallons (rare for construction, but relevant if you operate a large fleet depot).
Diesel (Retail UST): 100,000 gallons.

The "Gap Analysis" Column

Add a column to your template for "Compliance Status." This serves as your internal audit tool.

SDS on file: Do you have the current manufacturer SDS? (OSHA sets no expiration date; replace it when the manufacturer issues an updated version.)
GHS Rev: Is the hazard classification based on Rev 7?
Signal Word: Is it "Danger" or "Warning"?

Best Practices for Maintenance

An inventory is a living document.

Gatekeeping: No chemical enters the site without being logged.
Monthly Audits: Conduct spot checks. If you find a drum of solvent on the site that isn't on the list, your system has failed.
Archive Mode: Never delete a chemical from the list. Move it to an "Archived" tab. OSHA requires access to exposure records for 30 years.

By maintaining this "Ultimate Template," you turn the panic of the March 1st Tier II deadline into a simple export task, ensuring you avoid fines from both OSHA and the EPA.