Tier II Chemical Reporting in Michigan: Who Files & How

Short answer: if your Michigan facility stores a hazardous chemical at or above its EPCRA reporting threshold — generally 10,000 pounds, or as low as 500 pounds for an Extremely Hazardous Substance — you must file an annual Tier II chemical-inventory report by March 1, covering the prior calendar year. It goes to your State Emergency Response Commission (SERC), your Local Emergency Planning Committee (LEPC), and your local fire department. In Michigan the state environmental agency is EGLE (the Michigan Department of Environment, Great Lakes, and Energy). The hardest part is compiling an accurate inventory with quantities — which is exactly what SDSentry ($24 per location per month) keeps current for you year-round. Here is how Tier II works in Michigan.

Free, no signup: the SDS binder builder at sdsentry.0xpi.com/sds-binder.html turns a pasted list of the products you keep on site into one printable index of their current safety data sheets.

What Tier II is (and isn't)

Tier II is the annual chemical-inventory report required under Section 312 of the Emergency Planning and Community Right-to-Know Act (EPCRA). Its purpose is to tell fire departments and emergency planners what hazardous chemicals are stored at your facility, in what quantities, and where, so responders know what they are walking into. It is a separate obligation from OSHA Hazard Communication — the same chemicals on your shelves, but a different law and a different audience. Meeting your HazCom duties does not satisfy Tier II, and vice versa.

Who has to file in Michigan

The trigger is federal and applies the same way in Michigan as everywhere else. You must file Tier II if any hazardous chemical for which you are required to keep a safety data sheet is present at your facility at or above its reporting threshold at any point during the year:

• 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. A small clinic or shelter often stays under these limits, but bulk propane or diesel tanks, stored fuel, pool and spa chemicals, fertilizer, or a large supply of a single disinfectant can push you over — and EHS thresholds are low enough that a modest amount of the wrong chemical can trigger a report.

Where Michigan facilities submit

EPCRA sends every Tier II report to three places: your State Emergency Response Commission (SERC), your Local Emergency Planning Committee (LEPC), and your local fire department. In Michigan, the state's environmental program is administered by EGLE (the Michigan Department of Environment, Great Lakes, and Energy), and the Michigan SERC coordinates EPCRA reporting for the state.

Michigan facilities file electronically through Tier II Manager, the state's online reporting system, with reports going to Michigan EGLE in support of the Michigan SERC. You can find the system, filing instructions, and contacts on EGLE's Emergency Planning and Community Right-to-Know page: michigan.gov/egle. EGLE does not accept hard copies. Delivery to your LEPC and fire department depends on your county: EGLE's Michigan Facilities' Guide to SARA Title III lists the counties whose LEPCs and fire departments “can receive SARA Title III submittals online” — Allegan, Alpena, Antrim, Arenac, Benzie, Calhoun, Chippewa, Crawford, Eaton, Emmet, Genesee, Gogebic, Grand Traverse, Hillsdale, Ingham, Ionia, Iosco, Isabella, Kalamazoo, Kalkaska, Kent, Macomb, Mecosta, Midland, Monroe, Oakland, Oceana, Ogemaw, Oscoda, Otsego, Ottawa, Presque Isle, Van Buren, Washtenaw and Wayne. For every other county, “Reports MUST be mailed or emailed directly to LEPCs and fire departments.” State systems and instructions can change year to year, so confirm current details with EGLE before you file.

The deadline

The federal Tier II deadline is March 1 every year, for the previous calendar year, and Michigan follows that date. If you crossed a threshold at any point during the prior year, your report is due by March 1. Build in time before the deadline to gather quantities and have your preparer review them, because the last week of February is a poor time to discover your inventory list is out of date.

Are there Michigan state fees?

No. EGLE's Michigan Facilities' Guide to SARA Title III: “There is no fee associated with reports submitted in Tier II Manager.” The work in Michigan is compiling the inventory and, outside the counties listed above, getting copies to your LEPC and fire department.

What to have ready before you file

The report itself is mostly a structured list. What slows people down is assembling accurate underlying data. Before you start, have on hand:

• A complete chemical inventory for the location, with the product name and chemical identity for each item.
• The maximum quantity on site during the year and the average daily quantity, with units.
• Storage details — container type, pressure, temperature, and the specific location or building.
• Hazard information from each product's safety data sheet.
• Facility identifiers, emergency contacts, and (where required) latitude and longitude.

If you keep a current SDS library and a per-location inventory with quantities throughout the year, the February scramble largely disappears. See our guide on building a chemical inventory from scratch for a starting point.

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 so your preparer is not rebuilding the inventory by hand each February. It keeps a current SDS on file for every product, which is where most of the hazard and storage details on the report come from. It will not submit the report for you — you still file through Tier II Manager to Michigan EGLE and the Michigan SERC — but it turns the worst part, compiling and maintaining the data, into a download. Pair it with our HazCom compliance checklist so your OSHA and EPCRA obligations stay covered at the same time.

Track inventory for Tier II — free trial

Educational information only, not legal or compliance advice. Tier II thresholds, deadlines, submission methods, and any state fees change, and Michigan's specific process is set by the state. Verify your obligations with the Michigan SERC and EGLE, and with EPA's EPCRA resources at epa.gov/epcra, before you file — and consult a qualified professional for your situation.