Every reporting season, the same last-minute scramble happens at facilities that treat Tier II prep as a February task instead of a year-round one. Here's a practical checklist to work through before March 1, and what should ideally already be handled well before you get there.
DownloadPrintable Tier II checklist (PDF): the same eight steps with owner, date and evidence fieldsStep 1: Confirm your full facility list
Set your preparation schedule by working back from the due date. Tier II reports are due by March 1 and cover the previous calendar year; our guide to Tier II reporting deadlines also covers the event-driven Section 302 and 311 dates that don't wait for March.
Check
- Every facility that stored a reportable chemical at any point during the prior year is accounted for
- New facilities added during the year are included, and closed or sold facilities are handled per your state's requirements
- The reporting year is confirmed as the previous calendar year. For the report due March 1, 2027, that is January 1 to December 31, 2026
| Item | Detail |
|---|---|
| Required input | Last year's filing, the current site list from finance or operations, and records of sites opened, closed or sold during the year |
| Task | List every facility that kept SDSs for hazardous chemicals during the reporting year and decide which need a threshold review |
| Preparer / reviewer | Preparer: EHS coordinator. Reviewer: compliance or operations manager |
| Completion evidence | Dated facility list with reporting year, the reason any site was excluded, and an owner for each site |
Step 2: Reconcile your chemical inventory
Use the maximum amount present at any one time during the reporting year. The Tier II form also asks for the average daily amount and the number of days on-site, so reconcile all three while the records are open.
Check
- Every storage location has been physically checked, not just the main warehouse or the areas that are top of mind
- Peak quantities, not average or year-end quantities, are used for every chemical
- Chemicals in mixtures are accounted for individually where required
| Item | Detail |
|---|---|
| Required input | Receiving records, usage or production records, physical counts by location, and transfer records between buildings |
| Task | Reconcile records against physical counts; convert every quantity to pounds; find each chemical's highest same-day total across all locations |
| Preparer / reviewer | Preparer: site inventory owner. Reviewer: EHS coordinator, who rechecks unit conversions |
| Completion evidence | Reconciled inventory with maximum, average daily amount and days on-site per chemical, plus the conversion basis used |
Step 3: Verify every SDS is current
Check
- No chemical is being reported against an outdated or superseded SDS
- Any new chemical introduced during the year has a matching SDS on file
- Hazard classifications match the current SDS, not a prior year's data
| Item | Detail |
|---|---|
| Required input | The SDS library and the reconciled inventory from Step 2 |
| Task | Match every inventory item to its current SDS; capture CAS numbers, mixture composition and hazard classifications |
| Preparer / reviewer | Preparer: EHS coordinator. Reviewer: a second person spot-checks mixtures and any changed SDS |
| Completion evidence | Inventory-to-SDS match list with SDS revision dates, and a note of any supplier SDS requested |
Step 4: Run threshold calculations: federal and state
Compare each chemical's maximum on-site amount with the threshold that applies: 10,000 lb for hazardous chemicals, and 500 lb or the TPQ, whichever is lower, for EHSs. For mixtures and EHS components, our guide on how to calculate reporting thresholds walks through the method.
Check
- Every chemical has been checked against the federal 10,000 lb / 500 lb-or-TPQ thresholds
- State-specific thresholds have also been checked, where your state sets a lower or additional requirement
- Any chemical newly crossing a threshold this year has been flagged, not just carried over from last year's list
| Item | Detail |
|---|---|
| Required input | Reconciled maximum quantities from Step 2, EHS status from the EHS list (40 CFR part 355, Appendices A and B) and your state's instructions |
| Task | Compare every chemical against the federal threshold and any state requirement; sum EHS components across mixtures |
| Preparer / reviewer | Preparer: EHS coordinator. Reviewer: compliance manager |
| Completion evidence | Threshold worksheet showing quantity, threshold applied, decision and source for each chemical |
Step 5: Confirm your recipients
The federal recipients for Sections 311 and 312 are the SERC, the LEPC and the local fire department. Some states route submissions through one portal, but confirm in your state's instructions whether that upload reaches every recipient.
Check
- You know your correct SERC, LEPC, and fire department for each facility
- You've confirmed whether your state requires separate submissions to each, or a single combined filing
| Item | Detail |
|---|---|
| Required input | Your state's current Tier II instructions and official SERC, LEPC and fire-department contacts for each facility |
| Task | Record the recipients and delivery method for each facility, with the date you checked |
| Preparer / reviewer | Preparer: EHS coordinator. Reviewer: compliance manager |
| Completion evidence | Recipient list per facility with official source links and date checked |
Step 6: Check for related obligations beyond Tier II
Section 302 notification goes to the SERC and LEPC within 60 days after an EHS first reaches its TPQ at the facility. Section 311 submissions are due within three months after a chemical first reaches a threshold.
Check
- Any new EHS on-site above its TPQ has triggered the required Section 302 notification
- Section 311 SDS or chemical list submissions are current, not just Tier II
- Section 302 emergency coordinator details are current, and any change was reported to the LEPC within 30 days
| Item | Detail |
|---|---|
| Required input | Threshold results from Step 4, dates new chemicals first arrived, and past 302 and 311 submissions |
| Task | Confirm every new EHS at or above its TPQ was notified and every newly reportable chemical had its 311 submission |
| Preparer / reviewer | Preparer: EHS coordinator. Reviewer: compliance manager |
| Completion evidence | Copies of 302 notifications and 311 submissions, or a note that none were triggered this year |
Step 7: Generate and validate the report
Check
- The report is generated in the format your state and federal systems actually accept: .t2s for Tier2 Submit or E-Plan import, where applicable
- The report has been reviewed for completeness before submission, not just generated and sent
| Item | Detail |
|---|---|
| Required input | Reviewed facility, contact, chemical and storage data from Steps 1–6 and your state's accepted format |
| Task | Generate the report and review each field: identity and CAS, EHS flags, hazards, quantities, days on-site, storage locations |
| Preparer / reviewer | Preparer: EHS coordinator. Reviewer: the owner/operator or authorized representative who certifies the report |
| Completion evidence | Reviewed draft with reviewer comments resolved, and the signed certification |
Step 8: Submit and retain proof
Check
- The report has actually been submitted to every required recipient, not just generated and left in a draft state
- Confirmation of submission is saved and retained, in case it's ever needed for an audit
| Item | Detail |
|---|---|
| Required input | The certified report and the recipient list from Step 5 |
| Task | Submit to each required recipient and save every confirmation |
| Preparer / reviewer | Preparer: EHS coordinator. Reviewer: compliance manager confirms a confirmation exists for each recipient |
| Completion evidence | Submission confirmations, certified copy, threshold worksheet and correspondence stored together in the facility's records |
The real fix: don't wait for reporting season
Every item on this checklist is easier when it's handled continuously throughout the year rather than reconstructed in a two-week scramble before March 1. Facilities that track inventory, thresholds, and deadlines as they happen are simply confirming data at filing time, not discovering it.
If you'd rather not run this from spreadsheets, Tier II reporting software such as NeoTech's keeps inventory by location, alerts you before a threshold is crossed, schedules reminders with owners, and generates .t2s or PDF output, with an optional managed submission service. The review and certification steps above still belong to your team.
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.
SourceEPA Tier II Forms and InstructionsRegulatory statements in this article were checked against the official sources linked above on .