EPCRA Tier II checklist: what to gather before the March 1 deadline

If your facility stores hazardous chemicals above EPCRA reporting thresholds, the practical Tier II job is to gather last year's chemical inventory, SDS-backed names, maximum and average daily amounts, storage locations, emergency contacts, and state-specific filing instructions before March 1. The federal rule sets the baseline, but states can require different formats, lower thresholds, added fields, or different portal steps.

The short version: don't start with the portal. Start with the facility's threshold screen, chemical list, and storage map. The filing system is the last mile.

What Tier II is for

EPCRA Sections 311 and 312 are emergency-planning rules. Covered facilities report hazardous chemicals so state and local responders know what is stored on site, where it is stored, and who to contact in an emergency.

EPA's hazardous chemical inventory reporting page says facilities must submit the annual inventory by March 1 to the State or Tribal Emergency Response Commission, Local or Tribal Emergency Planning Committee, and the local fire department. EPA also notes that most states require the Tier II form, not the aggregate Tier I form.

That recipient detail matters. Before deadline week, confirm whether the portal handles distribution or whether you need separate delivery.

First, decide whether the facility is in scope

The federal baseline starts with whether the facility is required to maintain Safety Data Sheets under OSHA's Hazard Communication Standard. From there, EPA lists the common reporting thresholds:

• Extremely Hazardous Substances: 500 pounds or the Threshold Planning Quantity, whichever is lower
• All other hazardous chemicals: 10,000 pounds
• Retail gasoline stations: 75,000 gallons for gasoline and 100,000 gallons for diesel, when the specific underground-storage-tank conditions are met

Do this at the facility level, not the company level.

Also check state rules early. EPA's Tier II forms and instructions page states that states may add chemicals, set lower thresholds, or require more information than the federal baseline.

Build the threshold screen before the filing packet

The threshold question is not just what was on site at year-end. It is whether the chemical met or exceeded the applicable threshold at any time during the prior calendar year.

Before filing, build a simple screening worksheet for every chemical that could be close to a threshold. Capture:

• Chemical name as shown on the SDS
• Whether the chemical is an Extremely Hazardous Substance
• Applicable threshold and source of that threshold
• Maximum amount on site during the prior year
• Average daily amount, if the filing asks for it
• Number of days present on site
• Physical and health hazard categories
• Storage locations and conditions
• The business owner for the underlying record

EPA's general reporting guidance reinforces the lower-of-500-pounds-or-TPQ rule for Extremely Hazardous Substances in Tier II reporting. Use that federal baseline as the first pass, then verify the state or tribal portal for lower thresholds, added chemicals, fees, and recipient procedures.

The worksheet can stay simple, but it should be traceable. If the final report says a chemical was above threshold, someone should be able to find the SDS, the inventory basis, and the storage location without reconstructing the entire filing from memory.

Gather the chemical inventory

Build one row per reportable chemical, then reconcile it against purchasing, EHS, maintenance, warehouse, and production records. For each chemical, collect:

• The chemical name or common name as shown on the SDS
• The CAS number, if applicable and available in the state portal
• Whether it is an Extremely Hazardous Substance
• The physical and health hazard categories
• Maximum amount on site during the prior calendar year
• Average daily amount on site
• Number of days on site
• Physical state and any confidential-location handling

The most common miss is inventory ownership. Check ammonia refrigeration, propane tanks, battery rooms, backup-generator fuel, water-treatment chemicals, welding gases, compressed gases, cleaning products, seasonal chemicals, and materials stored for contractors, tenants, or affiliated operations at the same site.

Gather storage and location details

Responders need more than a chemical list. For each reportable chemical, gather:

• Building, room, tank, yard, cage, pad, or process-area location
• Storage type, such as aboveground tank, underground tank, tote, cylinder, drum, battery, railcar, or process vessel
• Storage conditions, such as ambient pressure, pressure, ambient temperature, or cryogenic
• Site map, location notes, and responder-access notes, if your state asks for them

Do not leave this to memory during filing. Tier II reports are responder-facing documents, so stale room names and moved tanks are real data-quality problems.

Gather facility and contact information

Tier II portals usually ask for more contacts than a normal business form. Prepare:

• Facility legal name and physical address
• Mailing address, if different
• Latitude, longitude, business activity, and state-required identifiers, if used
• Owner or operator name
• Emergency contact names, phone numbers, and 24-hour availability
• Non-emergency compliance contact
• Certifier name and title

Check phone numbers directly. A disconnected emergency contact number makes the report less useful even if the chemical math is right.

Confirm your state portal and recipients

Every facility should answer these questions before the final week:

• Which state, tribe, or territory portal applies?
• Does the portal distribute to the SERC or TERC, LEPC or TEPC, and fire department?
• Are local fire departments or LEPCs asking for a separate upload, email, or mailed copy?
• Does the state require fees, attachments, site plans, lower thresholds, or added chemicals?

EPA maintains a state Tier II reporting requirements index, but the state portal is the operational source for exact submission steps.

A clean filing packet

Before anyone certifies the report, assemble a packet with:

• Final chemical rows and SDS references
• Threshold notes for close-call chemicals
• Storage-location evidence
• Recipient list and portal confirmation
• Fees paid, if any
• Submission receipt and any separately sent local copies
• Certifier identity and certification timestamp

That packet is how a facility answers the later question: "What did we file, who certified it, and who received it?"

Where this fits with OSHA 300A

EPCRA Tier II and OSHA 300A are different filings, but they collide operationally because both land in the same late-winter compliance window. OSHA 300A posting starts February 1, OSHA electronic submission is generally due in early March for covered establishments, and EPCRA Tier II is due March 1.

Use the same facility-level thinking for both: one location, one set of facts, one deadline calendar, and one evidence trail.

Tier II and TRI are different EPCRA filings too. EPA's TRI reporting page states that submitting one does not satisfy the other. Still, the same chemical inventory can be an early warning signal that a July 1 TRI review belongs on the same calendar.

Start with the filing checker to confirm the OSHA side of the March deadline window and see other filings connected to the same facility. If the facility owes OSHA 300A filing, RegFile keeps review, certification, filing, and evidence together.

Start the filing checker ->

Public sources reviewed include EPA's hazardous chemical inventory reporting page, general reporting guidance, Tier II forms and instructions page, state Tier II reporting requirements index, and TRI reporting page, current as of July 9, 2026.

This is informational, not legal advice. Verify EPCRA scope, state requirements, thresholds, and recipient procedures against the applicable source documents.