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Starting January 1, 2018, the U.S. Environmental Protection Agency (EPA) will replace its five existing hazard categories used for hazardous chemical inventory form reporting (Tier II) with the hazard categories found in the revised Occupational Safety and Health Administration (OSHA) Hazard Communication Standard (HCS).

OSHA's HCS was recently revised to conform to the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS). Manufacturers and importers were required to develop standardized Safety Data Sheets (SDS) (formerly known as "Material Safety Data Sheets") and distribute them to downstream users of their chemicals. These changes in HCS and the physical/health hazard categories affect the Tier II reporting requirements under section 312 of the Emergency Planning and Community Right-to-Know Act (EPCRA).

The existing five hazard categories set to be replaced on January 1, 2018 are listed below.

  • Fire
  • Sudden Release of Pressure
  • Reactivity
  • Immediate (Acute)
  • Delayed (Chronic)

The new physical and health hazards adopted from the HCS are summarized in the following tables.

Physical HazardsHealth Hazard
Flammable (gases, aerosols, liquids, or solids)Carcinogenicity
Gas under pressureAcute toxicity (any route of exposure)
ExplosiveReproductive toxicity
Self-HeatingSkin Corrosion or Irritation
Pyrophoric (liquid or solid)Respiratory or Skin Sensitization
Oxidizer (liquid, solid, or gas)Serious eye damage or eye irritation
Organic peroxideSpecific target organ toxicity (single or repeated exposure)
Self-reactiveGerm cell mutagenicity
Pyrophoric gasSimply Asphyxiant
In contact with water emits flammable gasAspiration Hazard
Corrosive to metalHazard Not Otherwise Classified (HNOC)
Combustible Dust 
Hazard Not Otherwise Classified (HNOC) 

This change will require report submitters to edit every chemical in their Tier II report and select the new applicable hazards accordingly. EPA is modifying their Tier2 Submit software to include the new categories and is providing flexibility to allow states to modify their software by January 1, 2018. To find out if your state allows the use of Tier2 Submit software, review EPA's website . Facilities are expected to comply with reporting the new physical and health hazards on their Tier II reports when reporting for calendar year 2017. Tier II reports are due March 1 each year for chemicals present at the facility in the previous calendar year. To find out more information on RY 2017 Tier II requirements, visit the EPCRA fact sheet on EPA's website.

Trinity Consultants has nearly 50 offices nationwide and over 40 years' experience assisting industrial facilities achieving and maintaining environmental compliance. For help updating your Tier II report, reach out to a Trinity office near you by calling (800) 229-6655.