Tier II Report Hazard Changes 2018 | Regulatory updates

Tier II Reporting Season is Closing Quickly

Changes to Physical and Health Hazard Classifications

February 8th, 2019

As you may know, Tier II Reports (SARA Section 311/312) are due by March 1 to the State Emergency Response Commission, Local Emergency Planning Committee, and local fire department in most states. Tier II Reports detail materials stored on-site over a certain quantity threshold that the city, state, and/or federal have determined. These reports typically include facility contact information, chemical name, storage information, and the hazards associated with each chemical. More problematic—especially for companies with facilities in multiple jurisdictions, states, LEPCs, and fire departments—is that submission requirements for the report vary (submission requirements may include E-Plan, state-specific electronic database, email using Tier2Submit software, etc.). State-specific Tier II information can be found on the EPA’s website.

Since 2017, facilities have been required to report on the EPA’s updated list of Global Harmonized System (GHS) hazards. This change increased the hazard classifications from five to twenty-four. To determine the hazards, you should review Section 2 of your Safety Data Sheet.

Physical and Health Hazards (Effective January 1, 2018)

Physical Hazards (13)

Health Hazards (11)


Acute toxicity (any route of exposure)

Flammable (gases, aerosols, liquids, or solids)

Skin Corrosion or Irritation

Oxidizer (liquid, solid, or gas)

Serious eye damage or eye irritation


Respiratory or Skin Sensitization

Pyrophoric (liquid or solid)

Germ cell mutagenicity

Pyrophoric Gas



Reproductive toxicity

Organic peroxide

Specific target organ toxicity (single or repeated exposure)

Corrosive to metal

Aspiration hazard

Gas under pressure (compressed gas)

Simple Asphyxiant

In contact with water emits flammable gas

Hazard Not Otherwise Classified (HNOC)

Combustible Dust


Hazard Not Otherwise Classified (HNOC)


Tier II Reports are required when facilities trigger their state’s reporting thresholds for materials which present a physical or health hazard. The federal reporting thresholds are 10,000 pounds for hazardous chemicals and 500 pounds or the Threshold Planning Quantity (TPQ), whichever is less, for Extremely Hazardous Substances (EHS). However, many states have lower reporting thresholds, so you should check with your state reporting requirements. If you aren’t sure if your material contains an Extremely Hazardous Substance, check the ingredient list against the List of Lists for Section 302.

If the facility storage of EHS exceeds the Threshold Planning Quantity (SARA Section 302), additional requirements may need to be met. This includes designating a facility representative to participate in the local emergency planning process as a facility emergency coordinator and notifying the LEPC of relevant changes within 30 days after the changes have occurred. 

Here are a few helpful tips for completing your Tier II Report this year:

  • Get a jump start on reporting – don’t wait until the last week of February to start.
  • Review your state’s reporting requirements to determine if anything has changed.
  • Determine which chemicals will need to be reported, then review those specific SDS’s to determine the hazards.
  • Remember to include your lead-acid batteries from fork trucks and UPS Systems in your evaluation (sulfuric acid is considered an Extremely Hazardous Substance).
  • Maintain a copy of the report and paid invoice (if applicable) as proof of your submission.

Contact us today to get started on understanding the new hazard classifications for your Tier II Report.

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