Tier II Chemical Reporting in Missouri: Who Files & How
Short answer: if your Missouri 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 Missouri you file on the state's own Tier II site for the Missouri Emergency Response Commission (MERC), and pay a state fee with the form. 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 Missouri.
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 Missouri
The trigger is federal and applies the same way in Missouri 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 Missouri 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.
Missouri's SERC is the Missouri Emergency Response Commission (MERC), part of the State Emergency Management Agency. Missouri runs its own electronic Tier II filing site at apps1.mo.gov/MERC, and it only takes its own form — MERC: “Only the MISSOURI TIER II form is acceptable for EPCRA reporting in Missouri, we do not accept ‘Tier II Submit’ reports.” Filings are organized under the company name.
Filing with MERC does not automatically reach your LEPC and fire department. You can pay MERC to send them: “The Optional Distribution is a $10.00 charge per each facility. If you do not choose the Optional Distribution, then you are responsible for sending to the fire department” and the LEPC. Start from the MERC Tier II filing site.
State systems and instructions can change year to year, so confirm current details with the Missouri Emergency Response Commission before you file.
The deadline
MERC: “MISSOURI TIER II reports are due between January 1 and March 1 annually, the reporting information is for the previous year.” Under RSMo 292.606, the state fee is also due by March 1. Build in time before the deadline to gather quantities and have your preparer review them.
Are there Missouri state fees?
Yes. RSMo 292.606 sets Missouri's Tier II fees (checked Oct 2026):
- $100 per year from each reporting employer, submitted with the Tier II form (local governments and family-owned farm operations are exempt).
- An additional $20 for each hazardous substance or mixture once more than three are reported. The statute: “If more than three hazardous substances or mixtures are reported on the Tier II form, the employer shall submit an additional twenty-dollar fee for each hazardous substance or mixture.” MERC’s online fee sheet calculates the exact amount.
- Petroleum retail facilities pay no more than $50 per facility; pipeline operators pay $250 per county in which they operate.
- No employer pays more than $10,000 a year.
Fees are due by March 1, and “a late fee of ten percent of the total owed, plus one percent per month of the total, may be assessed by the commission.” The optional $10-per-facility distribution charge is separate.
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 the MERC Tier II site — 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
Frequently asked questions
Who do I send my Tier II report to in Missouri?
Missouri facilities file on the state's own Tier II site (apps1.mo.gov/MERC) for the Missouri Emergency Response Commission, which accepts only the Missouri Tier II form, not Tier II Submit. You must send copies to your LEPC and fire department yourself, or pay MERC's optional $10 per facility distribution charge.
When is the Tier II deadline in Missouri?
March 1. MERC states that Missouri Tier II reports are due between January 1 and March 1 annually for the previous year, and the state fee is due by March 1.
What are the Tier II reporting thresholds?
You report if a hazardous chemical that requires a safety data sheet is on site at or above 10,000 pounds at any time during the year, or at or above 500 pounds — or the Threshold Planning Quantity, whichever is lower — for an Extremely Hazardous Substance. Quantities are the maximum amount present at any one time.
Is there a Missouri state fee for Tier II?
Yes. Under RSMo 292.606 each reporting employer pays $100 a year plus an additional $20 for each hazardous substance or mixture when more than three are reported, capped at $10,000 a year. Petroleum retail facilities pay no more than $50 per facility and pipeline operators $250 per county. Local governments and family-owned farms are exempt.