Does OSHA require a chemical inventory? (the lead answer)
Yes. Under 29 CFR 1910.1200(e)(1)(i) every employer with hazardous chemicals must keep a written list of hazardous chemicals known to be present, identified by a product identifier that matches the chemical's label and safety data sheet (SDS). Construction is held to the identical duty through 29 CFR 1926.59 (adopts 29 CFR 1910.1200). This template gives you all 16 fields inspectors expect (9 of them OSHA-driven), plus the extra columns needed for EPA Tier II reporting — and exports to Excel, CSV, or a print-ready PDF.
What OSHA actually requires on the list
The HazCom standard mandates only one absolute element: a product identifier that matches the label and SDS. The standard does not dictate a column layout — but a list with only a name is not usable in an emergency and rarely satisfies an inspector. The columns below are the field-tested set that makes the inventory operationally compliant.
| Column | Why it's here | Required? |
|---|---|---|
| Product Name | Exact name from the container label and SDS Section 1. Must match across inventory, labels, and SDSs. | OSHA / best practice |
| Manufacturer | Manufacturer, importer, or responsible party from SDS Section 1. | OSHA / best practice |
| CAS Number | Chemical Abstracts Service number from SDS Section 3. Uniquely identifies the substance for Tier II reporting. | OSHA / best practice |
| Signal Word | "Danger" or "Warning" from SDS Section 2. Required on GHS labels. | OSHA / best practice |
| Hazard Class & Category | GHS hazard classification from SDS Section 2 (e.g. Flammable Liquid Cat 2). Use Rev 7 classes. | OSHA / best practice |
| GHS Pictograms | GHS pictogram codes from SDS Section 2 (e.g. GHS02, GHS07). Identifies hazard types at a glance. | OSHA / best practice |
| Hazard Statements (H-codes) | H-code(s) from SDS Section 2 (e.g. H225, H319). Describes nature and severity of the hazard. | OSHA / best practice |
| Physical State | Solid, Liquid, Gas, or Aerosol. Required for Tier II reporting and storage compatibility. | OSHA / best practice |
| Max Daily Amount | Highest quantity on site at any point (lbs or gal). EPCRA Tier II thresholds: 10,000 lb for most (non-EHS) hazardous chemicals; Extremely Hazardous Substances report at the lower of 500 lb or their Threshold Planning Quantity (40 CFR 370.10). | Recommended |
| Storage Location | Where the chemical is stored (e.g. Paint shed, Shop, Bay 3). Helps emergency responders. | Recommended |
| Container Type | Drum, Tote, Cylinder, Can, etc. Required for Tier II and storage compatibility checks. | Recommended |
| SDS on File (Y/N) | Confirm you have a current SDS. OSHA requires SDSs for each hazardous chemical. | OSHA / best practice |
| SDS Revision Date | Date of the SDS revision you have on file. Helps identify outdated SDSs. | Recommended |
| Last Verified | Date you last confirmed this row is accurate. Supports your audit trail. | Recommended |
| Responsible Person | Person or role responsible for this product at the site. | Recommended |
| Notes | Internal notes, batch info, PPE reminders, or special handling instructions. | Recommended |
GHS Rev 7 (HCS 2024): what changed for your hazard column
HCS 2024 aligns primarily GHS Revision 7. Your Hazard Class & Category column needs to accommodate the classes finalized by that rule:
- Desensitized Explosives App B.17
- Chemicals Under Pressure App B.3.2
- Aerosols (Categories 1–3, incl. new Cat 3 non-flammable) App B.3
You must be using updated labels, written program, and training by the dates below. Pull the exact classification straight from SDS Section 2 — full GHS Rev 7 class list:
ExplosivesFlammable gasesAerosols (Cat 1-3, Rev 7)Oxidizing gasesGases under pressureFlammable liquidsFlammable solidsSelf-reactive substancesPyrophoric liquids/solidsOxidizing liquids/solidsOrganic peroxidesCorrosive to metalsSkin corrosion/irritationSerious eye damage/irritationRespiratory sensitizerSkin sensitizerGerm cell mutagenicityCarcinogenicityReproductive toxicitySTOT single exposureSTOT repeated exposureAspiration hazardAcute toxicity (oral/dermal/inhalation)Hazardous to aquatic environmentChemicals under pressure (Rev 8, adopted in HCS 2024)Desensitized explosives (Rev 7)
| Who / what | Compliance date | CFR |
|---|---|---|
| Substances — manufacturers, importers, distributors | May 19, 2026 | 29 CFR 1910.1200(j)(2)(i) |
| Substances — employers (labels, program, training) | November 20, 2026 | 29 CFR 1910.1200(j)(2)(ii) |
| Mixtures — manufacturers, importers, distributors | November 19, 2027 | 29 CFR 1910.1200(j)(3)(i) |
| Mixtures — employers | May 19, 2028 | 29 CFR 1910.1200(j)(3)(ii) |
Tier II (EPA / EPCRA) — when the same inventory triggers a report
The OSHA inventory and the EPA Tier II report overlap, but Tier II is a separate EPA duty (EPCRA §312), not an OSHA one. If your on-site quantities cross these thresholds, you owe a Tier II report to your SERC, LEPC, and local fire department by March 1 each year (for the prior calendar year):
| Chemical category | Reporting threshold | CFR |
|---|---|---|
| Most hazardous chemicals (non-EHS) | 10,000 lb on site at any one time | 40 CFR 370.10(a) |
| Extremely Hazardous Substances (EHS) | Lower of 500 lb or the substance's Threshold Planning Quantity (TPQ) | 40 CFR Part 355, Appendix A (TPQ) |
| Retail gas-station gasoline (underground tanks) | 75,000 gal | 40 CFR 370.10(a)(2)(ii)-(iii) |
| Retail gas-station diesel (underground tanks) | 100,000 gal | 40 CFR 370.10(a)(2)(ii)-(iii) |
Applies only to gasoline/diesel at a retail gas station, in tanks entirely underground that complied with all applicable UST requirements (40 CFR Part 280, or an approved state program under Part 281) at all times during the preceding calendar year. Non-retail or above-ground fuel uses the normal 10,000-lb threshold. The four columns Tier II needs — Physical State, Max Daily Amount, Container Type, and CAS Number — are built into this template.
Two worked examples
1) Small drywall contractor. Joint compound, a few aerosols, and 5 gal of acetone in a paint shed. None of these is an EHS and the total is far under 10,000 lb, so no Tier II report is due — but OSHA still requires the written inventory + an SDS for each product. Filling the 9 required columns is enough.
2) Concrete plant storing anhydrous ammonia. Ammonia is an Extremely Hazardous Substance with a 500-lb TPQ. The Tier II trigger is the lower of 500 lb or that TPQ — so a 600-lb on-site quantity is reportable. Record the Max Daily Amount, Physical State (Gas), Container Type, and CAS number so the figures carry straight onto the Tier II form.
What to do next
- Find missing SDSs. Any row marked "N" in the SDS column is a gap — request the SDS from the supplier (it must be furnished free of charge).
- Label secondary containers to match your hazard column (29 CFR 1910.1200(f)(6)).
- Put the inventory where workers are — readily accessible during each work shift (29 CFR 1910.1200(g)(8)), alongside your SDS library and written program.
- Re-walk the site on a schedule and date each change in the Last Verified column.
Frequently asked questions
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, cross-referenced with SDSs. Product identifiers must match labels and SDSs. Construction employers are covered by 29 CFR 1926.59 (adopts 29 CFR 1910.1200), which makes the requirement identical.
What columns are legally required?
OSHA's HazCom standard mandates only one absolute item: a product identifier (the product name) that matches the label and SDS. Everything else on this template — signal word, hazard class, GHS pictograms, CAS number, SDS status, and storage location — is best practice that inspectors expect and that makes the list usable in an emergency. Tier II (EPA) reporting adds its own required fields.
When do I need to update the inventory?
Whenever you introduce a new hazardous chemical or remove one. OSHA expects the list to reflect what is actually present at the worksite. Review when receiving shipments or during walk-throughs, and date each change in the Last Verified column.
Where should the inventory be kept?
In the same system where workers access SDSs, readily accessible during each work shift (29 CFR 1910.1200(g)(8)). Your written HazCom program should describe where the inventory and SDSs are located.
How does GHS Rev 7 affect the inventory?
HCS 2024 aligns primarily GHS Revision 7, which adds and revises hazard classes — Desensitized Explosives, Chemicals Under Pressure, Aerosols (Categories 1–3, incl. new Cat 3 non-flammable). Your Hazard Class column should accommodate these. Employers must, as necessary, update any alternative workplace labeling, programs, and training for newly identified hazards by November 20, 2026 for substances and May 19, 2028 for mixtures.
Can I use this for Tier II (EPCRA) reporting?
Yes. This template includes fields needed for EPA Tier II reports: Physical State, Max Daily Amount, Container Type, and CAS Number. Note this is an EPA duty (EPCRA §312), separate from OSHA HazCom. Reporting is triggered at 10,000 lb for most (non-EHS) hazardous chemicals, but Extremely Hazardous Substances must be reported at the lower of 500 lb or their Threshold Planning Quantity (40 CFR 370.10). Tier II reports are due March 1 each year for the prior calendar year.
Is the inventory the same thing as my SDS binder?
No, but they are linked. The inventory is the master list of what hazardous chemicals are present; the SDS library is the set of detailed safety data sheets, one per product. OSHA requires both, and the product identifier on the list must match the SDS exactly so a worker can find the right sheet fast.
Sources & verification
- 29 CFR 1910.1200 — Hazard Communication (eCFR)
- 40 CFR Part 370 — EPCRA Tier I/Tier II reporting (eCFR)
- https://www.ecfr.gov/current/title-29/subtitle-B/chapter-XVII/part-1910/section-1910.1200
- https://www.federalregister.gov/documents/2026/01/15/2026-00653/hazard-communication-standard
- https://www.osha.gov/hazcom/rulemaking/extension
Regulatory figures verified 2026-10-05. This template is a planning aid, not legal advice, and does not by itself establish compliance. State-Plan states may add requirements.
Chemical inventory: the full guide →GHS Label Generator →HazCom Program Generator →SDS Gap Analyzer →29 CFR 1910.1200 explained →