Revisions to the Tier I and II Emergency and Hazardous Chemical Inventory Forms

The following is an update from EPA’s Superfund, TRI, EPCRA, RMP & Oil Information Center:

On July 13, 2012, EPA modified the EPCRA Section 312 Emergency and Hazardous Chemical Inventory Forms (Tier I and Tier II) to add new mandatory and optional data elements under the facility identification and contact information sections of both forms.  EPA also revised some existing data elements on the chemical reporting section of the forms to make reporting easier for facilities and make the forms more user-friendly for state and local officials.

In the final rule, EPA added the following new mandatory data elements to the Tier I and II forms: the facility’s latitude and longitude; identification numbers assigned under the TRI program and risk management program; whether the facility is manned or unmanned; the maximum number of occupants present at the facility at any one time; whether the facility is subject to EPCRA Section 302 and the Clean Air Act Section 112(r) risk management program; contact information for the individual responsible for completing the forms; emergency coordinator contact information for facilities subject to EPCRA Section 302; and e-mail addresses for the owner or operator and emergency contact.  The rule also revised the range codes on the forms for the maximum amount and the average daily amount of the hazardous chemical at the facility and added optional data elements for the facility phone number and parent company contact information.

In the rule, EPA also made revisions specific to the Tier II form.  Separate data fields were added for reporting pure chemical and mixtures; facilities must provide a description for storage types and conditions rather than reporting codes; and the form was revised to allow facilities to report any additional state or local reporting requirements or to voluntarily report hazardous chemicals below the reporting thresholds.

The final rule becomes effective on January 1, 2014, and facilities must comply with the new requirements on the Tier II inventory form starting reporting year 2013, which is due by March 1, 2014.  Additional information, including a copy of the final rule and fact sheet, is available at the following URL:

For questions regarding the revisions to the forms, please contact the Superfund, TRI, EPCRA, RMP & Oil Information Center at:

(800) 424-9346 — Toll Free
(703) 412-9810 — Metropolitan DC area and international calls
(800) 553-7672 — Toll Free TDD
(703) 412-3323 — Metropolitan DC area and international TDD

To speak with an Information Specialist, please call between 10:00 AM and 5:00 PM (EST), Monday through Thursday.  Information Specialists are available between 9:00 AM and 5:00 PM (EST) Monday through Friday during May, June, and July.

About Brian Chapin

PSM / RMP Compliance Consultant
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