EPCRA Tier II Reporting: Does Your Facility Need to File?
Short answer: you must file an EPCRA Tier II report if any hazardous chemical on site meets or exceeds its reporting threshold — generally 10,000 pounds, or as low as 500 pounds for an Extremely Hazardous Substance. Tier II is a yearly chemical-inventory report, due March 1, filed with your State Emergency Response Commission, Local Emergency Planning Committee, and fire department. It's separate from OSHA HazCom — same chemicals, different purpose: helping emergency responders know what's stored where. Here's how to tell whether it applies to you.
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Who has to file
Any facility required to keep a safety data sheet for a hazardous chemical must file Tier II if that chemical is on site at or above the reporting threshold at any point during the year. The general thresholds (40 CFR 370.10 (checked Oct 2026)) are:
- 10,000 lbs for most hazardous chemicals (those that require an SDS).
- 500 lbs — or the chemical's Threshold Planning Quantity, whichever is lower — for Extremely Hazardous Substances (EHSs) on EPA's list.
Quantities are based on the maximum amount present at any one time, aggregated across the facility.
When and where
Tier II reports are due annually by March 1 and cover the previous calendar year. They go to three places: your State Emergency Response Commission (SERC), your Local Emergency Planning Committee (LEPC), and your local fire department.
Do small facilities usually hit the threshold?
Often not — a typical shelter or clinic stocks cleaning and disinfection products in quantities well under 10,000 lbs. But it's worth checking the things that add up: bulk pool/spa chemicals, large propane or diesel tanks, stored fuel, fertilizer, or a sizeable bulk supply of a single disinfectant. EHSs have much lower thresholds, so a relatively small amount of the wrong chemical can trigger reporting. The only way to know is to track quantities.
States run their own systems
EPCRA is federal, but states collect Tier II differently — Texas (TCEQ), California (CERS), New York, and Florida (E-Plan) all have their own forms or portals, often with extra fields and sometimes a state fee. File through your state's system, not just the federal form.
Compare what every state charges in our Tier II fees by state table, and see which states set lower Tier II thresholds. State-by-state filing guides (agency, portal, deadline and thresholds): California, Texas, Florida, New York, Pennsylvania, Illinois, Ohio, Georgia, Michigan, North Carolina, Alabama, Alaska, Arizona, Arkansas, Colorado, Connecticut, Delaware, District of Columbia, Hawaii, Idaho, Indiana, Iowa, Kansas, Kentucky, Louisiana, Maine, Maryland, Massachusetts, Minnesota, Mississippi, Missouri, Montana, Nebraska, Nevada, New Hampshire, New Jersey, New Mexico, North Dakota, Oklahoma, Oregon, Rhode Island, South Carolina, South Dakota, Tennessee, Utah, Vermont, Virginia, Washington, West Virginia, Wisconsin, Wyoming.
How SDSentry helps
SDSentry tracks quantity and unit per item in your per-location inventory, flags items over a threshold you set, and exports an EPCRA Tier II CSV — with state-specific column layouts for TX, CA, NY, and FL — so your preparer isn't rebuilding the inventory by hand each February. It won't file for you, but it turns the worst part (compiling the data) into a download. Pair it with our HazCom compliance checklist to keep both obligations covered.
Track inventory for Tier II — free trial
Frequently asked questions
What is EPCRA Tier II reporting?
It is an annual chemical-inventory report required under the Emergency Planning and Community Right-to-Know Act. It tells fire departments and emergency planners what hazardous chemicals are stored where, and it is separate from OSHA HazCom.
Does my small facility have to file Tier II?
You file if any hazardous chemical on site meets or exceeds the reporting threshold, generally 10,000 pounds, or lower thresholds (often 500 pounds) for Extremely Hazardous Substances. Many small facilities do not hit these, but you should check your quantities.
When and where is Tier II filed?
By March 1 each year for the prior calendar year, to your State Emergency Response Commission, Local Emergency Planning Committee, and local fire department. Many states run their own online filing systems.
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