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Under EPCRA Section 312, all facilities that must prepare or have available safety data sheets (SDSs) under OSHA’s Hazard Communication Standard must submit a Tier I or Tier II inventory form. This submission is due annually on March 1.
Under Section 312, there are two categories of regulated substances. First, there are Extremely Hazardous Substances (EHSs) listed in Part 355, Appendix A and B. Second, there are hazardous chemicals - any chemical regulated by OSHA under Hazard Communication, ranging from 55,000 to 60,000 chemicals.
Each state manages Tier II reporting differently. Tier II reporting is required per EPCRA Section 312 for all facilities that must prepare or have available safety data sheets (SDSs) under OSHA’s Hazard Communication Standard. Facilities must submit a Tier II inventory form to the appropriate state implementing agency, although some states have developed their own forms. Some states require paper submissions, but the majority will provide a Tier II reporting website. Many states charge a fee per submission.
Extremely hazardous substance (EHS) means a substance listed in Appendices A and B of 40 CFR part 355.
Facility means all buildings, equipment, structures, and other stationary items that are located on a single site or on contiguous or adjacent sites and that are owned or operated by the same person (or by any person that controls, is controlled by, or under common control with, such person). Facility includes manmade structures, as well as all-natural structures in which chemicals are purposefully placed or removed through human means such that it functions as a containment structure for human use.
Hazard category is divided into two categories:
A summary of Missouri’s requirements includes the following:
Fees: May apply
Form required: Missouri Tier Two
Reporting agency: Missouri Emergency Response Commission
Electronic submission allowed/required: Required. However, if submitters did not select “Optional Distribution” when submitting online, they will still need to send signed hard copy reports to the Local Emergency Planning Committee and Fire Department/District.