EPA Updates EPCRA Tier II Hazard Categories to Match OSHA’s Hazard Communication Standard
- Aug 5
- 2 min read
The EPA has finalized changes to the Emergency Planning and Community Right-to-Know Act, or EPCRA, hazardous chemical inventory reporting requirements. The changes align the terminology and hazard categories used for EPCRA Sections 311 and 312 reporting with OSHA’s 2012 and 2024 Hazard Communication Standard updates.
What Is Changing?
For facility owners and operators, the main takeaway is: the hazard information reported on Tier II forms will more closely match the information already provided on your Safety Data Sheets (SDS).
Who Does the Rule Apply To?
EPCRA Sections 311 and 312 apply to owners and operators of facilities that are required under OSHA’s Hazard Communication Standard to prepare or maintain an SDS for a hazardous chemical.
What Does This Mean for My Facility?
This is a reporting-process change. The updated Tier II form will contain a larger and more detailed list of hazard categories. However, facilities should generally be able to select the applicable categories directly from the chemical’s SDS instead of interpreting how OSHA classifications fit within broader EPCRA groupings.
This should:
Reduce inconsistencies between SDSs and Tier II reports.
Reduce the amount of interpretation required when preparing reports.
Make it easier to transfer hazard information from an SDS to the inventory form.
Provide emergency planners and responders with more precise information about the hazards present at a facility.
What Should Facility Owners and Operators Do Right Now?
No immediate changes are required for the Tier II reports covering calendar year 2026.
When Will the Changes Apply?
The final rule was published on June 22, 2026, and becomes effective on August 21, 2026.
The compliance date for using the new hazard categories is January 1, 2028. EPA expects facilities to use the revised categories for their calendar year 2027 Tier II reports, due March 1, 2028.
Preparing for the Change
Facility owners and operators should expect a more detailed Tier II hazard-category section beginning with calendar year 2027 reporting.
Facilities that need the complete regulatory language, category tables, definitions, and section-by-section revisions can review EPA’s final rule, EPCRA Hazardous Chemical Inventory Reporting Requirements: Conformity With the 2024 OSHA Hazard Communication Standard, published at 91 FR 37022.
Navigating this reporting shift doesn't have to fall on your team alone. Alliance Technical Group's Compliance as a Service (CaaS360) includes Tier II Reporting under EPCRA Section 312 — from SDS review and hazard categorization to inventory calculations and LEPC/fire department submission — with one partner managing your compliance calendar.
