Tier II Chemical Reporting in Vermont: Who Files & How

Short answer: Vermont's threshold for most chemicals is 100 pounds, not 10,000. You upload a Tier2 Submit file to the Vermont SERC portal between January 1 and March 1, pay a per-chemical fee, and send separate copies to the statewide LEPC mailbox and your local fire department. It goes to your State Emergency Response Commission (SERC), your Local Emergency Planning Committee (LEPC), and your local fire department. Vermont bills a fee for each reported chemical and requires separate copies for the LEPC and fire department. 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 Vermont.

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 Vermont

“Vermont Table I” in the state's 2025 reporting package sets the thresholds for facilities handling chemicals that need a safety data sheet under VOSHA/OSHA:

• Extremely Hazardous Substances and all other hazardous chemicals, and pesticides: 100 pounds or the Threshold Planning Quantity, whichever is lower.
• Petroleum products and fuels: 10,000 pounds or greater. Table I lists road salts in this column too, but the package's own road-salt definition says 100 pounds, so confirm road salt with the state.
• Known human carcinogens as defined in VOSHA regulation 1910.1200(d): any amount.
• Explosives requiring a Vermont Department of Public Safety license: any amount of ANFO, dynamite, gel or slurry; initiators at 100 pounds or greater.

The package's examples of reportable chemicals at 100 pounds include argon, oxygen, CO2, acetylene, motor and lubricating oils, paint, ammonia, Freon, battery acid, lead in batteries, solvents, windshield washer fluid, pesticides and fertilizers. One exclusion helps small users: “Consumable products (those packages in containers weighing 40 lbs. or less, are not reportable).” Research laboratories have their own aggregate thresholds (10 pounds of all EHSs, 100 pounds of other chemicals).

Where Vermont 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.

Vermont's program is run by the Department of Public Safety for the Vermont State Emergency Response Commission. The 2025 cover letter: the SERC “requires facilities to submit Tier II reports by using the Environmental Protection Agency (EPA) Tier2Submit software program,” and “Electronic submission via .t2s file will be the only means of accepted submission.”

The report goes to three places, each its own way: the SERC through the TIER II Submit Portal, after which “an Invoice for the fees owed will be generated”; the Local Emergency Planning Committee as an electronic file emailed to DPS.StatewideLEPC@vermont.gov; and your local responding fire department as a hard copy or as that department requires. Start from Vermont's EPCRA program page.

State systems and instructions can change year to year, so confirm current details with the Vermont Department of Public Safety EPCRA program before you file.

The deadline

Vermont requires hazardous materials to be “reported annually between Jan 1 - March 1st for the preceding calendar year,” using that year's version of Tier2 Submit.

Are there Vermont state fees?

Yes, for each chemical. The 2025 package: “fees are based upon each reportable weight range per chemical. Fees are to be calculated for each reported material and NOT on the aggregate total.” The schedule, with “No Changes since 2016”:

• 100–999 lbs $40; 1,000–9,999 lbs $60; 10,000–99,999 lbs $100; 100,000–999,999 lbs $290; 1,000,000 lbs or greater $880.
• “Any Extremely Hazardous Substance (EHS) is $250 additional for any reportable quantity.”

State agencies, municipalities, other political subdivisions, non-profit corporations and farms (under 10 V.S.A. § 6001) are exempt from the fees.

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 Tier2 Submit — 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 Vermont's specific process is set by the state. Verify your obligations with the Vermont Department of Public Safety EPCRA program, and with EPA's EPCRA resources at epa.gov/epcra, before you file — and consult a qualified professional for your situation.