Frequently asked questions
- What file types are accepted for Tier II reporting?
- Who must report under sections 311/312?
- How often do I have to report?
- What is a reportable chemical?
- What are the hazardous chemical storage reporting requirements (EPCRA sections 311/312)?
- How do I find my NAICS code?
- What are the regulations?
Tier 2 Frequently Requested Information
1. What file types are accepted for Tier II reporting?
Only validated .t2s files may be uploaded through the process described in the instructions. While other file types may be uploaded as Supporting Documents (like PDFs and JPEGs), a .t2s file must be properly uploaded to complete your Tier II reporting process. Please note that Tier II files uploaded to the “Attachment” tab in the “Basic Information” tab under “My Account” are not accepted.
2. Who must report under sections 311/312?
If the company is required by OSHA to keep any Safety Data Sheet (SDS, formerly Material Safety Data Sheet, or MSDS) on file for hazardous chemicals stored or used in the workplace, and one or more of the chemicals is stored in quantities equal to or greater than the Threshold Planning Quantity (TPQ) for that chemical, then you must file a Tier II form for every year that any of the chemicals exceed the TPQ.
3. How often do I have to report?
Unless a new chemical exceeds a TPQ (requiring a Tier II report within 90 days), this is an annual report, due March 1, and covers the activity of the previous calendar year (i.e., calendar year 2017 reporting is due March 1 by 5:00 p.m. MST, 2018).
4. What is a reportable chemical?
If the U.S Occupational Safety and Health Administration (OSHA) requires your company to keep a SDSs/MSDSs 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.
Gasoline 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."
Section 302 EHSs:
- Extremely Hazardous Substance List by Chemical Name.
- Extremely Hazardous Substance List by Chemical Abstract Service Number.
5. What are hazardous chemical storage reporting requirements (EPCRA sections 311/312)?
Under OSHA regulations, employers must maintain a Safety Data Sheet (SDS) or a Material Safety Data Sheet (MSDS) for any hazardous chemicals stored or used in the workplace. Approximately 500,000 products have SDSs/MSDSs.
Section 311 requires facilities that have chemicals that require MSDSs, and that store more than the Emergency Planning and Community Right-to-Know Act (EPCRA) Threshold Planning Quantity (TPQ) for any of these chemicals, to submit a list of the chemicals, or copies of their SDSs/MSDSs. The Section 311 requirement is met by submitting a Tier II report for the applicable chemicals within 90 days of exceeding the threshold for that chemical.
Under Section 312, facilities covered by Section 311 must submit the Tier II form annually for all chemicals exceeding the reporting threshold in the previous calendar year. In Colorado, facilities meet this requirement by filing a single submission with the Colorado Department of Public Health and Environment. Tier II data submitted to the state is distributed to the LEPCs and local fire departments.
6. How do I find my NAICS code?
Both Tier2Submit and the Tier II Form now ask for the primary North American Industry Classification System (NAICS) code for your facility. For more information on NAICS codes and a NAICS search tool, see the U.S. Census Bureau’s Introduction to NAICS.