EPCRA Tier II Reporting
Last reviewed · By Chad Griffith
EPCRA Tier II is the annual hazardous chemical inventory report required under Section 312 of the Emergency Planning and Community Right-to-Know Act, codified at 40 CFR Part 370. Facilities storing hazardous chemicals above EPCRA threshold quantities must file by March 1 each year for the previous calendar year. Reports go to three recipients: the State Emergency Response Commission (SERC), the Local Emergency Planning Committee (LEPC), and the local fire department. Thresholds are 500 pounds (or TPQ if lower) for Extremely Hazardous Substances and 10,000 pounds for other hazardous chemicals. Civil penalties for non-filing reach $69,733 per day per violation under 2026 inflation-adjusted amounts.
Frequently Asked Questions
Who has to file EPCRA Tier II?
Facilities required to maintain a Safety Data Sheet under OSHA's Hazard Communication Standard for any chemical that exceeds EPCRA threshold quantities at any point during the reporting year. Common filers: manufacturers, gas stations (gasoline above 75,000 gallons), agricultural facilities, schools, hospitals (lab chemicals, medical gases), and fuel distributors.
What is the difference between Tier I and Tier II?
Tier I is a summary report showing aggregate quantities by hazard category (no chemical-specific identification). Tier II is the detailed report identifying each chemical, quantity, location, and storage conditions. Most states require Tier II reporting; Tier I is rarely accepted because it provides less detail. Tier II software (EPA's Tier2 Submit) generates both forms from the same input data.
What is the filing deadline?
March 1 each year for the previous calendar year's chemical inventory. Late filings are commonly cited during EPA inspections. Some states allow extensions for extraordinary circumstances; most do not.
Where do I file?
Three recipients: (1) State Emergency Response Commission (SERC) — most states use Tier2 Submit software or state portals; (2) Local Emergency Planning Committee (LEPC) for each district where chemicals are stored; (3) local fire department with jurisdiction over the facility. State submissions are typically electronic; LEPC and fire department submissions vary.
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