EPCRA §302 · §311 · §312EPCRA reporting
software solutions
Automate EPCRA 302, 311 and 312 Tier II reporting with chemical inventory management, threshold calculations, SDS integration and submission-ready reports.
NeoTech Elements is built for facilities that store or use hazardous chemicals — EHS managers at single-site manufacturers, compliance directors running twenty plants, and consultants filing on behalf of clients. One chemical inventory feeds every EPCRA obligation: enter a substance once and it flows into threshold screening, the Section 311 list, and the annual Tier II report for each facility it sits in.
- State Emergency Response Commission
- Local Emergency Planning Committee
- Local fire department
Emergency planning notification
A facility that has an Extremely Hazardous Substance on site at or above its Threshold Planning Quantity must notify its State Emergency Response Commission and Local Emergency Planning Committee, and name a facility emergency coordinator who takes part in local planning. TPQs are substance-specific and can be as low as one pound, so the trigger is often a small container nobody thought to count.
- ▸Screens inventory against the List of Lists. Every substance you hold is matched to the EHS list and its TPQ, so you know which containers can trigger §302 at all.
- ▸Alerts before the threshold, not after. A new receipt or a container change that would put a facility over a TPQ raises a flag with the date it happened.
- ▸Generates the notification. Facility identifiers, the designated emergency coordinator, and the substances that crossed their TPQ, assembled into a submission-ready letter.
- ▸Keeps the proof. Who was notified, on what date, for which substance — retained as a dated record for the next inspection.
SDS and hazardous chemical list reporting
If OSHA HazCom requires you to keep a Safety Data Sheet for a chemical, EPCRA §311 requires you to send that SDS — or a list of the hazardous chemicals grouped by hazard category — to your SERC, LEPC and local fire department. It is a one-time submission per chemical rather than an annual cycle, with an update due within three months when significant new information arrives or a new chemical becomes present above threshold.
- ▸Reads the SDS for you. AI extraction pulls hazard classes, CAS numbers and physical states out of the sheet, so the §311 list is built from your library rather than retyped.
- ▸Groups by hazard category. Chemicals are sorted into the categories the form expects, with the EHS entries called out separately against the lower threshold.
- ▸Tracks what has already been sent. Submission history per chemical per recipient, so an update covers only what actually changed.
- ▸Starts the clock on new chemicals. Anything newly present above threshold is flagged with its three-month update deadline.
Annual Tier II chemical inventory
Every facility over threshold files an emergency and hazardous chemical inventory covering the prior calendar year, due by March 1. Most states require the Tier II form, and most of the work is arithmetic: maximum amount on site, average daily amount, days present, storage type, location. NeoTech derives all of it from inventory records you already keep.
- ▸Calculates the quantities. Maximum and average daily amounts and days on site, computed per chemical per facility from your inventory movements.
- ▸Applies the thresholds. The 10,000 lb hazardous-chemical limit and the 500 lb / TPQ EHS limit are applied per chemical, per site, so the report includes exactly what it should.
- ▸Maps the storage detail. Container types, pressure and temperature conditions, and storage locations carried into the Tier II fields that ask for them.
- ▸Outputs .t2s and PDF. An electronic file for EPA Tier2 Submit and state systems that accept it, plus a PDF of the same report for your records.
- ▸Rolls last year forward. Next March you are editing a filing, not rebuilding one — with a diff showing what changed since the last submission.
Threshold calculations, done per chemical and per site
Reporting thresholds are the part teams get wrong most often, because they apply per chemical at each individual facility — not across the company — and because the EHS limit is whichever is lower of two numbers. NeoTech evaluates them continuously against live inventory instead of once a year.
| Chemical category | Reporting threshold | Applies to |
|---|---|---|
Hazardous chemicals requiring an SDS under OSHA HazCom | 10,000 lb | §311 · §312 |
Extremely Hazardous Substances Listed at 40 CFR 355 Appendices A and B | 500 lb or the TPQ, whichever is lower | §311 · §312 |
EHS present at or above its Threshold Planning Quantity | TPQ (substance-specific) | §302 |
Gasoline at a retail fuel facility All tanks combined, where USTs are in compliance | 75,000 gal | §312 |
Diesel at a retail fuel facility All tanks combined, where USTs are in compliance | 100,000 gal | §312 |
Federal minimums shown. States may set lower thresholds, require additional chemicals, or ask for reporting below these limits — NeoTech applies the rule for the state each facility files in.
From Safety Data Sheet to filed report, without a spreadsheet in between.
Build the inventory
Upload SDS PDFs; AI extraction structures each one and inventory is recorded by facility and location.
Screen the thresholds
Every chemical is checked against the 10,000 lb, 500 lb / TPQ and state limits, continuously.
Generate the report
§302 notification, §311 list, or the annual §312 Tier II form — assembled from the same data core.
File and archive
Export .t2s or PDF, record the submission, and keep the dated trail for the next inspection.
.t2s for the portal, PDF for the binder
Section 312 filings are submitted electronically in most states. NeoTech produces the .t2s file EPA's Tier2 Submit and many state systems accept, and the same report as a PDF for internal review, the fire department copy, and your records.
Federal rules, fifty sets of state details
EPCRA sets the floor; states decide how filing actually works. Some accept the federal .t2s, others run their own portals. Fees, opening dates, extra chemicals and lower thresholds all vary. NeoTech holds the rule per state so a multi-site filer isn't reconciling six sets of instructions by hand.
- ▸Per-state submission format and portal destination
- ▸State-specific thresholds applied ahead of the federal minimum
- ▸Filing fees and deadlines tracked per facility, not per company
- ▸SERC, LEPC and fire department recipients recorded for each site
Release notification
A release of an Extremely Hazardous Substance or a CERCLA hazardous substance above its reportable quantity requires immediate notification to the SERC and LEPC — and to the National Response Center for CERCLA substances — followed by a written report. This is Element 08 on the platform roadmap: reportable quantities tracked against your inventory, the right agencies identified per substance, and each filing logged with a full trail.
EPCRA reporting questions
What is EPCRA reporting software?
EPCRA reporting software maintains the chemical inventory and Safety Data Sheet records a facility needs under the Emergency Planning and Community Right-to-Know Act, compares stored quantities against reporting thresholds, and produces the Section 302, 311 and 312 submissions that go to the State Emergency Response Commission, Local Emergency Planning Committee and local fire department.
When is a Tier II report due?
Section 312 inventory reports covering the prior calendar year are due by March 1 each year. Some states open their portals earlier and charge filing fees, and several set lower reporting thresholds than the federal minimums.
What is the difference between Section 311 and Section 312?
Section 311 is a one-time submission of a Safety Data Sheet or a list of hazardous chemicals, updated within three months when significant new information arrives or a new chemical becomes present above threshold. Section 312 is the annual inventory of how much of each chemical was on site, filed on the Tier II form.
What is a .t2s file?
A .t2s file is the electronic submission format produced by EPA's Tier2 Submit software and accepted by many state programs for Section 312 Tier II filings. NeoTech generates .t2s alongside a PDF of the same report.
Do I have to file a Section 302 notification every year?
No. Section 302 notification is triggered the first time an Extremely Hazardous Substance is present at or above its Threshold Planning Quantity, with notification due within 60 days. After that you update when the facility, the emergency coordinator or the substances present change.
Can a consultant file for multiple client facilities?
Yes. Facilities are managed separately with their own inventory, thresholds and reports, and Professional covers up to ten facilities on one subscription. Beyond ten, Enterprise is quoted per facility.
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Try a Tier II run on one site. Free.
1 facility · 100 SDS · 10 AI extractions. No credit card — the account simply goes read-only when the trial ends.