# EPCRA Tier II and Form R Reporting Readiness Checklist > Source: https://netray.co/tools/epcra-tier-ii-reporting-readiness-checklist > Publisher: Netray (netray.co), AI and integration engineering for ERP and manufacturing systems. > Section: Free Tools ## Short answer A step by step checklist for EPCRA Tier II inventory reporting and Toxics Release Inventory Form R, covering thresholds, data collection and submission. ## Category ehs-workforce ## Region United States ## Industry Manufacturing ## Audience - EHS manager - Environmental coordinator - Compliance officer ## Tool **Kind:** checklist **Groups:** #### Scope and applicability **Items:** **Text:** Confirm which facilities must report under EPCRA Section 312 (hazardous chemicals with an SDS requirement under OSHA) **Critical:** true **Text:** Check each chemical against the 10,000 lb threshold for hazardous chemicals **Critical:** true **Text:** Check extremely hazardous substances against 500 lb or the threshold planning quantity, whichever is lower **Critical:** true Confirm whether the site meets Section 313 criteria: covered NAICS code, 10 or more full time employee equivalents, and manufacture, process or otherwise use thresholds Document any exemptions you rely on and the basis for each Check state rules, since some states set lower thresholds or use their own reporting system #### Inventory data collection **Items:** **Text:** Pull the current SDS list and match each entry to a chemical inventory record **Critical:** true **Text:** Record maximum amount on site on any one day during the calendar year **Critical:** true Record average daily amount and number of days on site Capture physical and health hazard categories from the SDS Record storage types, pressure and temperature conditions, and storage locations Reconcile purchasing, receiving and issue transactions against the inventory totals Identify mixtures and decide whether to report the mixture or its components Remove discontinued products and add new ones introduced during the year #### Toxics Release Inventory (Form R) **Items:** **Text:** Screen chemicals against the current EPCRA Section 313 list **Critical:** true **Text:** Calculate manufactured, processed and otherwise used quantities per chemical against thresholds **Critical:** true Estimate releases to air, water, land, and transfers off site, with the estimation method documented Document waste management quantities such as recycling, energy recovery and treatment Review supplier notifications on listed toxic chemicals in mixtures Record the technical contact, certifying official and facility identifiers Keep calculation worksheets and supporting records for the required retention period #### Submission and follow up **Items:** **Text:** Submit the Tier II report to the state emergency response commission, local emergency planning committee and local fire department by March 1 **Critical:** true **Text:** Submit Form R by July 1 for the previous calendar year **Critical:** true Confirm any state specific portal, fee or format requirements Retain a copy of the submitted report and proof of submission Provide fire department access for site visits when requested Update emergency contacts and facility emergency coordinator details Log lessons learned and data gaps for next year's collection **Scoring Note:** Critical items are those that commonly lead to missed filings or incorrect thresholds. Thresholds and dates are federal, so confirm against the current EPA rule text and your state requirements before you rely on them. ## Content **Intro:** EPCRA reporting has two annual cycles with different rules: Tier II chemical inventory under Section 312 and Toxics Release Inventory Form R under Section 313. This checklist helps you work through scope, data collection and filing for both. **Sections:** #### How to use the checklist **Body:** Work through the groups in order and tick items as you complete them. Start in January so you have time to reconcile inventory data. Export the checklist as a PDF or Excel file to share with the EHS team, purchasing and the plant manager, and keep the completed copy as evidence of your reporting process. **Bullets:** - Assign an owner to each group - Complete scope checks before collecting detailed data - Review critical items last, before submission #### Method behind the thresholds **Body:** Section 312 compares the maximum amount of each hazardous chemical on site at any one time with the threshold. For most hazardous chemicals this is 10,000 pounds, and for extremely hazardous substances it is 500 pounds or the threshold planning quantity if lower. Section 313 uses annual throughput thresholds for manufacture, process or otherwise use of listed chemicals, so the numbers come from usage rather than storage. #### Example **Body:** A machine shop stores 6,000 lb of cutting fluid concentrate and 5,000 lb of cleaning solvent. Each product is assessed on its own, so neither alone crosses 10,000 lb. However, if the SDS lists a hazardous component present in both products, the component quantities may need to be aggregated depending on the mixture approach you choose. Document the reasoning. #### Common mistakes **Body:** Using year end inventory instead of the maximum on any day, forgetting to include chemicals in contractor stored tanks or trailers, and treating Tier II and Form R as one report. A second pattern is relying on purchasing records alone, which misses chemicals brought in by customers or maintenance contractors. **Cta:** If your chemical inventory and purchasing data sit in your ERP, we can help build a repeatable extract for maximum and average quantities each January. **Faq:** #### When is the Tier II report due? **Answer:** Federal EPCRA Section 312 requires Tier II reports by March 1 each year for the previous calendar year. Some states set different dates or use their own systems, so confirm with your state emergency response commission. #### When is Form R due? **Answer:** Form R under Section 313 is due July 1 for the previous calendar year. Facilities that meet the NAICS, employee and chemical threshold criteria must file for each covered chemical. #### What is the difference between Tier II and Form R? **Answer:** Tier II reports chemical inventories and storage for emergency planning. Form R reports releases and waste management quantities for specific toxic chemicals. They have separate thresholds, deadlines and recipients. #### Does this checklist replace legal advice? **Answer:** No. It is a preparation aid based on federal requirements as generally understood. Rules change and states differ, so verify against current EPA guidance and your state agency before submitting. ## Search terms tier ii reporting checklist, epcra 312 checklist, form r reporting tri checklist, epcra tier ii due march 1, tri form r july 1 deadline, hazardous chemical inventory threshold 10000 pounds, extremely hazardous substance threshold planning quantity, epcra compliance checklist --- Talk to an engineer: https://netray.co/contact?intent=erp_ai | Machine catalog: https://netray.co/agent/catalog.json