Tier II Reporting

Tier II hazardous chemical inventory reporting 

We now require electronic Tier 2Submit files, sent via email or flashdrive. We now require electronic Tier2Submit files, sent via email. We can accept only files using U.S. Environmental Protection Agency (EPA) Tier2Submit software or the exact Tier2Submit file format. If we can’t easily process your submission, we’ll ask you to correct and resend it. If your file is too large to be sent through the email system, please send the file on a flashdrive or USB drive to the address above. 

If mailing a flashdrive, you must include a sheet of paper with a contact name and phone number, in case of problems. If you can’t file electronically because of an inadequate Internet connection and/or computer, you can report by paper. 

Defining a reportable chemical 

If the U.S Occupational Safety and Health Administration (OSHA) requires your company to keep a Safety Data Sheet (SDS, formerly Material Safety Data Sheet, or MSDS) on file for any chemicals stored or used in the workplace, and the chemical(s) is stored in quantities equal to or greater than the Threshold Planning Quantity (TPQ) for that chemical, then you must report it. 

The TPQ for these chemicals is either: 

500 pounds or the TPQ listed (whichever is lower) for the 356 chemicals listed under Section 302, 
also known as Extremely Hazardous Substances (EHS); 

or 10,000 pounds for any other chemical. 

Section 302 EHSs: 

EPA tools.
Extremely Hazardous Substance List by Chemical Name.
Extremely Hazardous Substance List by Chemical Abstract Service Number. 

Exception: In 1999, EPA excluded gasoline held at most retail gas stations from EPCRA 311/312 reporting for gasoline and/or diesel, if stored in underground tanks. This exemption doesn’t apply to fuel mixtures containing more than 10 percent ethanol. 

Motor oil, antifreeze and diesel meet the OSHA definition of a "hazardous chemical." 

Contrary to what some oil companies are listing on MSDS sheets, OSHA considers motor oil a hazardous chemical. This 1997 letter on the OSHA website was written in response to a memorandum stating that antifreeze, oil products and diesel weren’t hazardous.

For additional information:



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