EPCRA Tier II Inventory Reporting Overview

EPCRA Sections 311 and 312 requires annual reporting by March 1st for facilities storing chemicals above stated thresholds. Reporting must be submitted along with safety data sheets and a list of the chemicals to each of the following:

i) The Local Emergency Planning Committee (LEPC)

ii) The State Emergency Planning Commission, and

iii) The fire department with jurisdiction over the facility.

The reporting is used by emergency response departments so they are aware of how to respond in the event of an emergency. Generally the reporting threshold is 10,000 pounds; however, it is lower for chemicals considered extremely hazardous substances (EHS), e.g., sulfuric acid.

A comprehensive list of chemicals subject to EPCRA reporting is available here: https://www.epa.gov/system/files/documents/2025-04/consolidated-list-of-lists-updated-april-2025.pdf.

The filing is a federal requirement under 40 CFR Part 370 - Hazardous Chemical Reporting: Community Right-to-Know.

Examples of Capacities that trigger thresholds:

i) 1,400 gallon diesel fuel * 7.2 lb/gall diesel fuel (density of diesel fuel) = 10,080 pounds

ii) One 2,500 gallon propane tank * 4.2 lb/gall propane = 10,500 pounds

iii) Three lead-acid battery forklifts often exceed the 500 pound threshold for extremely hazardous substances.

FAQs

What are the penalties for not reporting?

Fines can range from a few hundred dollars to thousands depending on the severity of omissions and the harm caused by not reporting.

Who does this apply to?

EPCRA applies to facilities that:

  • Store fuels, oils, or chemicals;

  • Have aboveground storage tanks;

  • Manufacturing or warehouse facilities;

  • Marinas, utilities, or public works facilities.

What guidance has the State of Florida published related to this?

The State of Florida has published the following related to Tier II reporting and Nursing Homes and Assisted living facilities ~ https://www.floridadisaster.org/globalassets/dem/response/technological-hazards/epcra/florida-generator-tier-ii-flyer-2021.pdf

What guidance has the USEPA published related to this?

The USEPA has extensive descriptions of the regulation at ~ https://www.epa.gov/epcra/hazardous-chemical-inventory-reporting

My storage tank is registered with the County and FDEP. Aren’t I in compliance.

Registering a storage tank does not automatically satisfy the EPCRA Tier II reporting requirements.

https://portal.floridadisaster.org/SERC/External/EPCRA/Florida%20Petroleum%20and%20Lubrication%20Tier%20II%20Flyer%202021.pdf.

How can Lion Point assist?

Free EPCRA Applicability Evaluation

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Quote a Flat Fee

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We’ll quote you a flat fee based on your current chemical storage, which will determine the level of effort required. There is no obligation and no sales pressure.


Tier II Report Preparation and Submittal

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A qualified environmental professional will review your facility’s information to determine whether your facility is subject based on its current storage practices. Most reviews are completed within 1-2 business days.

We’ll work with you to gather the information we need, e.g., site maps, facility contact information, safety data sheets, etc. to make the reporting process as easy as possible.


Clear Communication and Trust

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You can reach us anytime via our contact page or email. We focus on client satisfaction and aim to provide practical environmental compliance solutions to make our client’s lives easier.

Get in Touch

If you're interested in obtaining a free EPCRA applicability evaluation please complete the form with a few details about your facility. We'll review your message and get back to you within 48 hours.