EPCRA Tier II and Form R Checklist (Free, PDF)

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9 critical items still open - these are the highest-risk gaps.

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Scope and applicability

Confirm which facilities must report under EPCRA Section 312 (hazardous chemicals with an SDS requirement under OSHA)CRITICALCheck each chemical against the 10,000 lb threshold for hazardous chemicalsCRITICALCheck extremely hazardous substances against 500 lb or the threshold planning quantity, whichever is lowerCRITICALConfirm whether the site meets Section 313 criteria: covered NAICS code, 10 or more full time employee equivalents, and manufacture, process or otherwise use thresholdsDocument any exemptions you rely on and the basis for eachCheck state rules, since some states set lower thresholds or use their own reporting system

Inventory data collection

Pull the current SDS list and match each entry to a chemical inventory recordCRITICALRecord maximum amount on site on any one day during the calendar yearCRITICALRecord average daily amount and number of days on siteCapture physical and health hazard categories from the SDSRecord storage types, pressure and temperature conditions, and storage locationsReconcile purchasing, receiving and issue transactions against the inventory totalsIdentify mixtures and decide whether to report the mixture or its componentsRemove discontinued products and add new ones introduced during the year

Toxics Release Inventory (Form R)

Screen chemicals against the current EPCRA Section 313 listCRITICALCalculate manufactured, processed and otherwise used quantities per chemical against thresholdsCRITICALEstimate releases to air, water, land, and transfers off site, with the estimation method documentedDocument waste management quantities such as recycling, energy recovery and treatmentReview supplier notifications on listed toxic chemicals in mixturesRecord the technical contact, certifying official and facility identifiersKeep calculation worksheets and supporting records for the required retention period

Submission and follow up

Submit the Tier II report to the state emergency response commission, local emergency planning committee and local fire department by March 1CRITICALSubmit Form R by July 1 for the previous calendar yearCRITICALConfirm any state specific portal, fee or format requirementsRetain a copy of the submitted report and proof of submissionProvide fire department access for site visits when requestedUpdate emergency contacts and facility emergency coordinator detailsLog lessons learned and data gaps for next year's collection

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.

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How to use the checklist

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.

Assign an owner to each group
Complete scope checks before collecting detailed data
Review critical items last, before submission

Method behind the thresholds

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

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

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.

Frequently Asked Questions

When is the Tier II report due?

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?

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?

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?

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.

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.

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