EPCRA 101: Understanding Sections 302, 311, and 312

Section 302: Emergency planning notification

Section 302 is about one-time notification, not annual reporting. If your facility has an Extremely Hazardous Substance (EHS) present at or above its Threshold Planning Quantity (TPQ), you're required to notify your State Emergency Response Commission (SERC) and Local Emergency Planning Committee (LEPC) that your facility is subject to emergency planning requirements, within 60 days after your facility first becomes subject.

This notification also requires designating a facility emergency response coordinator, someone the LEPC can contact if there's an incident, and telling the LEPC who that is within the same 60 days. Unlike Tier II reporting, Section 302 notification isn't something you file every year; it's triggered when you first reach the threshold. After that, you report relevant changes to the LEPC within 30 days and provide information the LEPC requests promptly.

Section 311: Hazardous chemical reporting (SDS submission)

Section 311 applies to facilities that must maintain Safety Data Sheets under OSHA's Hazard Communication Standard and have hazardous chemicals at or above the reporting thresholds. Those facilities submit SDSs (or a list of the hazardous chemicals covered by SDSs) to the SERC, LEPC, and local fire department. The purpose is straightforward: if there's ever an emergency, responders need to know what's actually in the building before they walk in.

Many facilities satisfy Section 311 by submitting a list of hazardous chemicals rather than every individual SDS, though specific requirements vary by state and by what your LEPC or fire department requests. The submission is due within three months after the facility becomes subject, meaning within three months of a chemical first being present at or above its threshold. Section 311 is typically a one-time submission, updated when new hazardous chemicals are introduced or significant changes occur, and it doesn't reset every year the way Tier II reporting does.

Section 312: The Tier II report

Section 312 is what most people mean when they say "Tier II reporting," and it's the annual obligation most facilities spend the most time on. If you had a hazardous chemical present at or above 10,000 lbs, or an EHS at or above 500 lbs or its TPQ (whichever is lower), at any one time during the previous calendar year, you're required to file a Tier II report. The comparison uses the maximum amount present at any one time, and mixtures have their own counting rules; our guide shows how to calculate reporting thresholds step by step.

Unlike 302 and 311, Tier II is annual, due by March 1 for the prior calendar year, and it requires more detail: individual chemical or mixture identification, physical and health hazard categories, maximum and average daily quantities, the number of days the chemical was present, and general storage location and conditions.

The Tier II goes to the SERC, the LEPC and the local fire department. Some states route it through a single state portal or system, so check your state's instructions for how each recipient is served.

Sections 302, 311 and 312 side by side

The key distinction is between emergency-planning notification and inventory reporting. Section 302 tells planners that a facility holds an EHS at a level that makes it part of local emergency planning; it is about EHSs only. Sections 311 and 312 are inventory reporting: they cover every hazardous chemical at or above its threshold and describe what is on-site and, for Tier II, how much and where.

Walking one facility through all three checks

Facility B (fictional) stores two items during reporting year 2026. Product A is a hazardous chemical that is not an EHS; its highest amount on-site at one time was 14,000 lbs. Chemical X is an EHS with an assumed TPQ of 1,000 lbs (a fictional value, so always read the real TPQ from the official list). Chemical X first reached 500 lbs on April 2, and its highest amount at one time was 800 lbs.

1. Section 302 check: is any EHS at or above its TPQ? Chemical X peaked at 800 lbs, below its 1,000 lb TPQ, so no Section 302 notification is triggered for it.
2. Section 311 check: is any hazardous chemical at or above its threshold? Product A (14,000 lbs) is at or above 10,000 lbs. For Chemical X, the threshold is the lower of 500 lbs and its 1,000 lb TPQ, which is 500 lbs, and it reached that on April 2. Facility B owes an SDS or chemical list for each, within three months of the date each first reached its threshold.
3. Section 312 check: using the same thresholds and each chemical's maximum for the year, both Product A and Chemical X go on the Tier II for 2026, due by March 1, 2027.
4. Change check: if Chemical X had peaked at 1,200 lbs instead, it would also be at or above its TPQ, and Facility B would owe a Section 302 notification within 60 days of first reaching 1,000 lbs, in addition to the other two filings.

That's why completing one filing doesn't automatically take care of the others. A Tier II filed the following March doesn't meet a Section 311 deadline that fell three months after a chemical arrived, or a Section 302 notice due within 60 days, and the Section 302 notice doesn't go to the fire department. If your state accepts one submission for more than one purpose, confirm that in its written instructions rather than assuming it.

How the three sections relate to each other

It helps to think of them in sequence rather than as three unrelated rules:

A facility can be subject to one, two, or all three sections depending on what it stores and in what quantities, so it's worth confirming your specific obligations rather than assuming only Tier II applies, since 302 and 311 triggers are sometimes overlooked.

State programs add their own layer on top of this federal outline: portals, forms, recipients, fees and sometimes extra chemicals or thresholds. Check the current instructions for each state where you have a facility. Our Tier II requirements by state pages and EPA's state Tier II reporting requirements and procedures directory are good starting points.

• Section 302 tells your local responders that your facility exists as an emergency-planning concern in the first place.
• Section 311 tells them specifically what hazardous chemicals you have, so they know what they're dealing with.
• Section 312 (Tier II) tells them, every year, how much of each chemical was actually on-site, in enough detail to plan for a worst-case scenario.

Common points of confusion

• Section 302 and 311 are largely one-time or as-needed; Section 312 (Tier II) is annual.
• Recipients differ slightly by section and by state. SERC, LEPC, and fire department aren't always the same three contacts for every submission.
• Thresholds differ: 10,000 lbs for ordinary hazardous chemicals, 500 lbs or TPQ (whichever is lower) for Extremely Hazardous Substances.
• "Present at any point during the year" means the maximum quantity, not an average, which is a common source of underreporting.

Official source

The federal requirements described in this article are established under the Emergency Planning and Community Right-to-Know Act (EPCRA). Always verify current state-specific rules with your SERC.

Section 302 requirements are in 40 CFR part 355; Sections 311 and 312 are in 40 CFR part 370 and summarized on EPA's EPCRA Sections 311-312 page.