How EPCRA Tier II reporting works
EPCRA Tier II is an EPA program, not an OSHA standard. It comes from the Emergency Planning and Community Right-to-Know Act (EPCRA §312), implemented at 40 CFR Part 370. It exists so that local fire departments and emergency planners know what hazardous chemicals are stored in their jurisdiction before they respond to an incident. The duty is triggered by a simple test: if OSHA’s Hazard Communication standard (29 CFR 1910.1200) already requires you to keep a Safety Data Sheet for a chemical, and you store that chemical at or above the reporting threshold at any one time during the year, you must report it on Tier II.
That is the connection most contractors miss: your OSHA HazCom chemical inventory is the same starting list you screen for Tier II — but the threshold check, the agency, and the March 1 deadline are all EPA’s.
EPCRA Tier II reporting thresholds (2026)
A chemical is reportable when the maximum amount present at any one time during the calendar year meets or exceeds the threshold for its category (40 CFR 370.10(a)). These figures are unchanged for 2026.
| Chemical category | Reporting threshold | CFR |
|---|---|---|
| Hazardous chemical — non-EHS (any chemical that requires an SDS) | 10,000 lb | 40 CFR 370.10(a) |
| Extremely Hazardous Substance (EHS) | lower of 500 lb or the substance TPQ | 40 CFR Part 355, Appendix A (TPQ) |
| Gasoline in retail underground storage tanks (UST) | 75,000 gal | 40 CFR 370.10(a)(2)(ii)-(iii) |
| Diesel in retail underground storage tanks (UST) | 100,000 gal | 40 CFR 370.10(a)(2)(ii)-(iii) |
Retail UST fuel thresholds apply only to gasoline/diesel in tanks entirely underground at a retail gas station in compliance with 40 CFR Part 280; otherwise fuel uses the normal 10,000-lb threshold.
Common EHS Threshold Planning Quantities
For an Extremely Hazardous Substance, you compare your on-site amount against the lower of 500 lb or the substance’s TPQ from 40 CFR Part 355, Appendix A. When the TPQ is below 500 lb, the TPQ governs:
| EHS | CAS | TPQ | Effective Tier II threshold |
|---|---|---|---|
| Chlorine | 7782-50-5 | 100 lb | 100 lb |
| Ammonia (anhydrous) | 7664-41-7 | 500 lb | 500 lb |
| Sulfuric acid | 7664-93-9 | 1,000 lb | 500 lb |
| Hydrogen fluoride / Hydrofluoric acid | 7664-39-3 | 100 lb | 100 lb |
| Formaldehyde | 50-00-0 | 500 lb | 500 lb |
The full EHS list has roughly 355 substances. For any EHS not shown, look up the TPQ in 40 CFR Part 355, Appendix A and enter it in the screener above.
Worked examples
1. Paint contractor with 8,000 lb of a flammable coating. The coating is a non-EHS hazardous chemical, so the threshold is 10,000 lb. 8,000 lb is below threshold → not reportable on Tier II (though it still needs an SDS and HazCom labeling under OSHA).
2. Water-treatment plant storing 250 lb of chlorine. Chlorine is an EHS with a TPQ of 100 lb. The threshold is the lower of 500 lb or the 100-lb TPQ = 100 lb. 250 lb exceeds 100 lb → reportable, and it must be on the Tier II submission by March 1.
3. Retail gas station with 60,000 gal of gasoline in underground tanks. The retail-UST threshold for gasoline is 75,000 gal. 60,000 gal is below that → not reportable. The same fuel above ground, or at a non-retail facility, would instead use the 10,000-lb threshold and almost certainly be reportable.
What to do next
- Screen your full inventory with the tool above and download the worksheet for your records.
- Transfer reportable chemicals onto the official Tier II form (EPA’s Tier2 Submit software or your state’s portal). This worksheet is a screening aid, not the filing itself.
- Submit to all three recipients — your State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC), Local fire department with jurisdiction over the facility — on or before March 1 (40 CFR 370.45) for the prior calendar year.
- Keep proof of submission and re-screen whenever your chemicals, quantities, or storage locations change.
Frequently asked questions
Is EPCRA Tier II an OSHA requirement?
No. EPCRA Tier II is an EPA program under the Emergency Planning and Community Right-to-Know Act (EPCRA §312), implemented at 40 CFR Part 370. It is separate from OSHA's Hazard Communication standard (29 CFR 1910.1200). The two are linked, though: you only have to report a chemical on Tier II if OSHA's HazCom standard already requires you to keep a Safety Data Sheet for it AND you store it above the threshold. The reporting duty, thresholds, agency, and March 1 deadline are EPA's, not OSHA's.
What are the Tier II reporting thresholds?
Under 40 CFR 370.10(a): a non-EHS hazardous chemical is reportable at 10,000 lb or more present at any one time during the year. An Extremely Hazardous Substance (EHS) is reportable at the LOWER of 500 lb or its Threshold Planning Quantity (TPQ) from 40 CFR Part 355, Appendix A. Gasoline and diesel held entirely in underground tanks at a retail gas station (in compliance with 40 CFR Part 280) use higher thresholds of 75,000 gallons (gasoline) and 100,000 gallons (diesel) under 40 CFR 370.10(a)(2)(ii)-(iii).
When is the Tier II report due and who receives it?
Tier II reports are due on or before March 1 each year, covering the prior calendar year (40 CFR 370.45). The report must be submitted to your State Emergency Response Commission (SERC), your Local Emergency Planning Committee (LEPC), and the local fire department with jurisdiction over your facility. Most states require electronic filing through Tier2 Submit or a state portal; there is no federal filing fee, though some states charge their own.
Why is the EHS threshold not just a flat 500 lb?
Many Extremely Hazardous Substances have a Threshold Planning Quantity below 500 lb, and when that happens the lower TPQ governs. For example, chlorine and hydrogen fluoride each have a TPQ of 100 lb. The rule (40 CFR 370.10) compares your on-site amount against the LOWER of 500 lb or the substance's TPQ, so this tool asks for the TPQ when you mark a chemical as an EHS.
Does this tool look up TPQ values for me?
It includes a small built-in lookup for a few common Extremely Hazardous Substances (chlorine, anhydrous ammonia, sulfuric acid, hydrogen fluoride, formaldehyde) with their TPQ from 40 CFR Part 355, Appendix A. The full EHS list has roughly 355 substances, so for any other EHS you should look up the TPQ in Appendix A and enter it manually.
What hazard categories go on the Tier II form?
The current Tier II form uses the OSHA/EPCRA hazard classes that align with GHS: the physical hazards and health hazards reported as the applicable categories (for example flammable, gas under pressure, combustible dust, carcinogen, acute toxicity, skin/eye corrosion, respiratory or skin sensitizer). Pull the exact hazard classification from each chemical's Safety Data Sheet, Section 2.
What happens if I miss the March 1 Tier II deadline?
EPCRA §325 authorizes civil penalties for failing to file a complete and timely Tier II report. Because amounts are inflation-adjusted annually, confirm the current maximum with EPA before relying on a figure. The practical risk is real: late or missing reports are a common EPCRA enforcement target, and a fire department arriving without your inventory on file is a safety problem. File on time, keep proof of submission, and re-screen whenever your chemicals or quantities change.
Sources & verification
- https://www.ecfr.gov/current/title-40/chapter-I/subchapter-J/part-370/subpart-B/section-370.10
- https://www.ecfr.gov/current/title-40/chapter-I/subchapter-J/part-370/subpart-C/section-370.45
- https://www.ecfr.gov/current/title-40/chapter-I/subchapter-J/part-355/appendix-Appendix%20A%20to%20Part%20355
- https://www.epa.gov/epcra/tier-ii-forms-and-instructions
EPCRA thresholds verified 2026-06-23 against the eCFR and EPA. This tool is a screening aid for planning only — it is not legal advice and not a substitute for the official Tier II filing required by your state.
EPCRA Tier II: the full guide →Chemical inventory template →SDS gap analyzer →Secondary container labels →OSHA HazCom standard →