Changes to EPCRA Sections 311 and 312 hazardous chemical reporting forms (Tier I and Tier II) will b

Summary of Changes: The Environmental Protection Agency (EPA) has decided to revise existing hazard categories currently used for hazardous chemical inventory reporting under EPCRA Section 311 (Tier I) and Section 312 (Tier II) to conform to the hazard classes now used in the Occupational Safety and Health Administration (OSHA) revised Hazard Communication Standard (HCS). EPA has decided to replace the existing five hazard categories:

  1. Fire

  2. Sudden Release of Pressure

  3. Reactive

  4. Immediate (Acute)

  5. Delayed (Chronic)

with the specific hazard classes listed in the revised OSHA Hazard Communication Standard:Physical Hazard Health Hazard Flammable (gases, aerosols, liquids, or solids)CarcinogenicityGas under pressureAcute toxicity (any route of exposure)ExplosiveReproductive toxicitySelf-heatingSkin Corrosion or IrritationPyrophoric (liquid or solid)Respiratory or Skin SensitizationPyrophoric GasSerious eye damage or eye irritationCorrosive to metalSpecific target organ toxicity (single or repeated exposure)Oxidizer (liquid, solid or gas)Aspiration HazardOrganic peroxideGerm cell mutagenicitySelf-reactiveSimple AsphyxiantIn contact with water emits flammable gasHazard Not Otherwise Classified (HNOC)Combustible DustHazard Not Otherwise Classified (HNOC)

EPA will be modifying the Tier2 Submit software developed for reporting under section 312 to include the new physical and health hazards. For states that have their own reporting software for section 312, EPA is providing flexibility to allow states to modify their software by January 1, 2018. Facilities are required to comply with reporting the new physical and health hazards on their Tier II inventory form for reporting year 2017, by March 1, 2018.


Effective Date: This final rule was effective June 13, 2016.

Compliance Date: The compliance date is January 1, 2018.

Note: These changes will not affect reporting for the current year 2016 and existing forms and software will be used for completing Tier II reports which must be completed by March 1, 2017.

For more information, please contact Bob King, CIH, CSP, at 508-970-0033 ext. 113 or


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