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Chemical Reporting for Tier II

If you have any hazardous chemicals or extremely hazardous substances above a reporting threshold present at any one time you need to submit a Tier II report.

What is a hazardous chemical?

There is no complete list of all chemicals that are considered hazardous. However, the Safety Data Sheet (SDS), formerly called a Material Safety Data Sheet (MSDS), can help you determine if a product is "hazardous”. If you are required by Occupational Safety and Health Administration (OSHA) to keep a SDS on file for any chemicals stored or used at your facility, those chemicals are typically considered hazardous under the Tier II Program.

Do I have an extremely hazardous substance (EHS)?

Extremely hazardous substances (EHS) include only the 355 chemicals listed under Section 302 of the Emergency Planning and Community Right-to-Know Act. The reporting threshold for extremely hazardous substances is 500 lbs or the threshold planning quantity (TPQ), whichever is less.

What is a mixture?

If more than one component is listed on the SDS, the substance is a mixture. However, you only have to report the chemical as a mixture if the components are easily separated.

Is a mixture that has less than one percent of a hazardous chemical considered hazardous?

You do not have to count a hazardous chemical present in a mixture if the concentration is less than or equal to 1%, unless the chemical is carcinogenic.

If the chemical is carcinogenic then it is reportable if the concentration is greater than 0.1%. (40 CFR 370.14

Are all compressed gases considered hazardous?

Yes, ALL compressed gases are considered hazardous because they pose a risk of sudden release of pressure or an explosion hazard because their contents are under very high pressure.

As defined by the OSHA Hazard Communication Standard, compressed gases are "those gases or mixtures of gases that have an absolute pressure of 40 pounds per square inch (psi) at 70° F or an absolute pressure exceeding 104 psi at 130° F, regardless of the pressure at 70° F."

The only exemptions are compressed gases used in a research laboratory, hospital or other medical facility under the direct supervision of a technically qualified individual.