Ask the Expert, Chemicals

What Makes a Chemical Reportable under Tier II Reporting?

Q: When questioning whether a chemical is reportable under SARA 312 Tier II what’s the best way to make that determination? Other than exceeding the 10,000 lb quantity on hand, what makes a chemical reportable under Tier II?

A: Chemicals reportable under the EPCRA Section 312 Tier II requirements include any substance for which a facility must maintain a Material Safety Data Sheet (MSDS) or Safety Data Sheet (SDS) under the OSHA Hazard Communication Standard (29 CFR 1910). Over 500,000 products are required to have a MSDS/SDS.

The reporting threshold is 10,000 pounds for most chemicals. However, for Extremely Hazardous Substances (EHSs), the reporting threshold is either 500 pounds or the Threshold Planning Quantity (TPQ), whichever is lower. A list of EHSs and their TPQs can be found at 40 CFR 355, Appendix A and Appendix B.

There are also higher reporting thresholds for gasoline (75,000 gallons) and diesel fuel (100,000 gallons) stored at retail gas stations.