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Comparison of Tier II, TRI, and 112(r) Requirements

Compares the requirements for Tier II, TRI, and Section 112(r).

The Emergency Planning and Community Right-to-Know Act (EPCRA) requires businesses that store and/or manufacture, process, or use certain chemicals to complete the Tier II (EPCRA 311 and 312) Report and/or the Toxics Release Inventory (EPCRA 313) Report, also called the Form R.

Section 112(r) of the Clean Air Act focuses on risk management for accident prevention. While these three programs have similar reporting elements, they have significant differences outlined in the following table.

Question Tier II Toxics Release Inventory (TRI) Section 112(r)
Who administers this program?




U.S. Environmental Protection Agency (EPA)


What is a general description of the program? Emergency Planning: reporting significant amounts of hazardous chemicals maintained at fixed facilities for emergency planning purposes. Community Right-to-Know: reporting on air emissions, waste disposal, and wastewater discharges. Risk Management for Accident Prevention: responding to emergencies and planning to prevent accidents.
Who needs to submit reports? Any company storing chemicals that could present a physical or health hazard in amounts that exceed the threshold limits.

Companies that exceed the threshold limits and:

  • Have 10 employees or more.
  • Treat hazardous waste.
  • Distribute chemicals.
  • Mine metals or coal.
  • Have petroleum bulk stations (wholesale).
  • Are electric utilities.

Industry sector must be covered by the NAICS code list found in Table 1 of the March 2021, EPA publication EPA-740-B-21-001, Toxic Chemical Release Inventory Reporting Forms and Instructions, and manufacture, process, or otherwise use more than the triggering amount for that classification of a TRI chemical.

Businesses such as:

  • Farm cooperatives.
  • Chemical manufacturers.
  • Chemical distributors.
  • Metal product manufacturers.
  • Food processors.
  • Drinking water systems.
  • Utilities.

If they exceed the threshold amounts.

What reporting is required?

One-time Emergency Planning Letters for facilities that have certain hazardous chemicals in specified amounts.

Tier II Chemical Inventory Reports submitted online through STEERS.

Form A: a shorter report for companies that meet the qualifications for reporting but have lower chemical on-site amounts and off-site transfers.

Form R: an inventory of on-site releases and off-site waste transfers of substances (not products) listed under TRI.

The EPA requires facilities to use TRI-MEweb to submit TRI reporting forms (except for trade secret information ).

Risk Management Plans should include:

  • hazard assessment
  • prevention program
  • emergency response program

Submit electronically through RMP*eSubmit .

When is the report or plan due? Annual reports are due March 1st of every year for the previous calendar year.

Initial reports are due within 90 days of a new facility or new chemical surpassing the reporting threshold. Similarly, update reports are required to be submitted within 90 days of any significant change to an existing facility report.
July 1st of every year for the previous calendar year. June 20, 1999, initially; update every 5 years.
Is there a list of reportable chemicals with thresholds? No, TCEQ relies on OSHA's definition of "hazardous chemical" to determine which products may need to be reported. The Extremely Hazardous Substances (EHS) list Adobe Acrobat PDF Document shows only a portion of the reportable chemicals. Yes, on the EPA’s TRI-Listed Chemicals site Yes, the 112(r) list in 40 CFR §68.130 .
How many reportable chemicals are on this threshold list? There are 355 chemicals on the EHS list; however, there is no set list of all reportable hazardous substances. There are 770 toxic chemicals and chemical categories. There are 77 acutely toxic substances and 63 flammable gases and volatile liquids.
What are the thresholds?

Each limit represents the peak storage quantity of that chemical over a year.

  • 10,000 lb for hazardous substances that are not considered an EHS.
  • 500 lb or the threshold planning quantity, whichever is less, for 355 chemicals listed on the EHS list.

The TRI program classifies chemicals as normal TRI chemicals or as persistent, bioaccumulative toxins (PBT).

If you manufacture or process more than 25,000 lb in a year or use more than 10,000 lb of non-PBT (persistent and bio-accumulative toxins) TRI chemicals, then report any on-site releases or off-site waste transfers of those chemicals.

Find reporting thresholds for PBT chemicals in section B.4 of the March 2021, EPA publication EPA-740-B-21-001, Toxic Chemical Release Inventory Reporting Forms and Instructions.

Threshold quantities for each chemical are in 40 CFR §68.130.

If your peak storage quantity of any chemical exceeds the limit at any point in the year, report to EPA.

All quantities in the table below represent peak storage quantity at your facility. The Tier II column shows reporting thresholds and threshold planning quantities (TPQs) for each chemical listed.

Report Tier II TRI Section 112(r)
Anhydrous Ammonia
CAS #7664-41-7

Reporting threshold: 500 lb
TPQ: 500 lb

There is no minimum release reporting threshold. Any amount of air, water, or toxic waste release of that TRI chemical must be reported on Form R if the company meets all of these criteria:

  • Has a NAICS code found in Table 1 of the current EPA publication 260-R-10-001, Toxic Chemical Release Inventory Reporting Forms and Instructions.
  • Has 10 employees or more
  • Manufactures, processes, or otherwise uses more than the triggering amount for that classification of a TRI chemical in one year.
10,000 lb
CAS #7782-50-5

Reporting threshold: 100 lb
TPQ: 100 lb

2,500 lb
Hydrogen Fluoride
CAS #7664-39-3

Reporting threshold: 100 lb
TPQ: 100 lb

1,000 lb
Toluene 2,4 Diisocyanate
CAS #584-84-9

Reporting threshold: 500 lb
TPQ: 500 lb

10,000 lb

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