Tier II Hazard Categories Are Changing - What Does That Mean For Your Facility?

By Jordan Coulam, Environmental Specialist

EPCRA Tier II reports now have more hazard classifications - what does this mean for EHS professionals?

The new hazard classifications are aligned with the OSHA Hazard Communication Standards, or what should be present on an SDS. This reflects the 2012 and 2024 OSHA Haz Com requirements.

The rule goes into effect on August 21, 2026, but EPA expects facilities to report in line with the new rule starting in the reporting year 2027. The first affected Tier II report will be due March 1, 2028. 

The full rule is available here: 

www.federalregister.gov

Technical Amendments to the EPCRA Hazardous Chemical Inventory Reporting Requirements To Conform to the 2024 OSHA Hazard Communication Standard

The Environmental Protection Agency is proposing to conform the Emergency Planning and Community Right-to-Know Act hazardous chemical inventory reporting regulations to the Occupational Safety and Health Administration's Hazard Communication Standard amendments of 2012 and 2024. The Emergency...

What does this mean for facilities?

• This is a good opportunity to ensure all of your SDSs are up to date.

• Starting with the March 1, 2028 report, all Tier II reports will need to include the new hazard classes (that match the updated SDSs).

• There will be increased scrutiny of hazard classifications on Tier II reports. In the past, discrepancies between Haz Com and Tier II standards could account for small errors in the Tier II report. Going forward, there will be less leniency for these mistakes, which could result in fines for your facility.

• Discrepancies in your Haz Com program could result in issues for Tier II reporting. More visibility on hazards tracking means mistakes are more likely to be found during an audit. 

Tier II reporting can be difficult - collecting inventory from different data sources, compiling hazards, and collating all of that information into one report. Toolkit’s purpose-built Tier II tool reduces the time your facility spends on the report, while ensuring you are up to date with the regulatory requirements. 

Tier II Tool centralizes all of your chemical records in one place, while ensuring consistency with other environmental reports such as TRI and emissions reporting. Facilities answer a simple, guided questionnaire to automatically generate Tier II reporting for the SERC, LEPC, and local emergency responders. Your facility can be confident in its Tier II reporting, as regulatory updates such as those to the EPCRA hazard classes are deployed regularly. 

Curious how your team could save time and money on Tier II reporting?

Contact Toolkit