Tier II Chemical Reporting in Oregon: Who Files & How

Short answer: Oregon runs its own, much broader program. Under the Community Right to Know and Protection Act you report to the Oregon State Fire Marshal any SDS-required hazardous substance stored at 500 pounds, 500 gallons or 500 cubic feet or more — and far less for highly toxic substances and explosives — with the annual report filed in CHS Manager between January 1 and March 1. It goes to your State Emergency Response Commission (SERC), your Local Emergency Planning Committee (LEPC), and your local fire department. Oregon's CHS Manager report reaches the LEPC, fire department and EPA, and an annual Hazardous Substance Possession Fee is billed separately. 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 Oregon.

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 Oregon

Oregon's thresholds are far below the federal 10,000 pounds. The Oregon State Fire Marshal's Reportable Quantities sheet (revised January 2026) says a hazardous substance is “any substance required by Oregon-OSHA to have a Safety Data Sheet (SDS) or any substance for which a hazard is identified on any available SDS,” and that it must be reported if the maximum amount on site meets the reportable quantity “at any one time for more than 24 hours” during the previous calendar year:

• Most substances: liquids 500 gallons or more; solids 500 pounds or more; non-liquefied gases 500 cubic feet or more; liquefied gases 500 gallons or more.
• Highly toxic substances and explosives: liquids 5 gallons; solids 10 pounds; gases 20 cubic feet.
• Radioactive substances: any amount (sealed sources meeting OAR 333-100-0005 excepted).
• Extremely Hazardous Substances: the federal Threshold Planning Quantity or 500 pounds, whichever is less, even when below the Oregon reportable quantity.
• Retail gas stations: 75,000 gallons of gasoline or 100,000 gallons of diesel in compliant underground tanks.

At 500 pounds, ordinary businesses — a store with pallets of cleaners, a shop with drums of solvent, a farm supply with fertilizer — can be reporting facilities in Oregon when they would not be anywhere else.

Where Oregon 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.

Oregon's program is run by the Oregon State Fire Marshal (OSFM) under the Oregon Community Right to Know and Protection Act (ORS 453.307-414), working with the Oregon State Emergency Response Commission and the LEPCs. The annual report is filed online in the Community Right to Know Hazardous Substance Manager (CHS Manager), and “facilities are required to upload a current SDS to CHS Manager, for each reported hazardous substance.”

Oregon calls itself a one-stop shop: “By submitting an annual hazardous substance inventory report, to CHS Manager, the facility has fulfilled the obligation to report. The Local Emergency Planning Commission (LEPC), fire department, and EPA has access to the information in the report.” Oregon also requires mid-year updates: “Any facility that introduces a new hazardous substance, in a reportable quantity, at any location must file an Update report within 30 days.” Start from OSFM's hazardous substance storage reporting page.

State systems and instructions can change year to year, so confirm current details with the Oregon State Fire Marshal before you file.

The deadline

OSFM: “The 2025 Annual Report was due January 1 - March 1, 2026, through the CHS Manager online program.” The same January 1 to March 1 window applies each year for the previous calendar year, and new substances need an Update report within 30 days, whenever they arrive.

Are there Oregon state fees?

Yes, and it is separate from the report. OSFM: “Oregon law (ORS 453.402) requires facilities to pay a fee based on the substance they report in the highest aggregate (maximum) amount. The fee is calculated using a fee schedule set in OAR 837-090 graduated to account for the degree of hazard the billable substance presents.” This Hazardous Substance Possession Fee also funds the Department of Environmental Quality's Toxic Use Reduction program and the Orphan Site Fund. OSFM says the 2026 fee statements are mailed by the Department of Revenue on or around November 15, 2026. Look up your rate in OAR 837-090 or with OSFM rather than estimating it.

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 CHS Manager — 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 Oregon's specific process is set by the state. Verify your obligations with the Oregon State Fire Marshal, and with EPA's EPCRA resources at epa.gov/epcra, before you file — and consult a qualified professional for your situation.