Information for Industry - Facility Hazardous Chemical Reporting Requirements

Requirements for submission:

SARA Title III, Section 312, requires that the owners or operators of any facility that is required to prepare or have available a material safety data sheet (MSDS) for a hazardous chemical under the Occupational Safety and Health Act of 1970 must prepare and submit an emergency and hazardous chemical inventory form if the quantity of those hazardous chemicals present equals or exceeds established threshold reporting quantities. The chemical inventory form to be submitted is known as a Tier II report form. If required, this form must be submitted by March 1 of each year. To assist in determining if a Tier II report needs to be submitted, refer to the "SARA Title III Reporting Requirements: Tier II" decision chart.

What are the reporting thresholds established under Section 312?

  • Extremely Hazardous Substance (EHS) - 500 lbs. or the threshold planning quantity (TPQ), whichever is less.
  • Hazardous chemicals - 10,000 lbs. of an OSHA hazardous chemical.

Who must receive the Tier II report?

If a Tier II report is required, it must be submitted to the Bucks County LEPC, the Pennsylvania Department of Labor and Industry and the fire department with jurisdiction over the facility.

Are any hazardous chemicals exempt from the Tier II reporting requirement?

SARA Title III Section 311.(e) provides for certain exceptions to the definition of a "hazardous chemical". These include: Certain FDA regulated products; substances present as a solid in any manufactured item to the extent exposure to the substance does not occur under normal use; certain household packaged products; substances used in R&D labs, hospitals or other medical facilities; substances used in routine agricultural operations or fertilizers for sale by a retailer.

Who can answer questions regarding Tier II report submission requirements?

Contact the office of the Bucks County Emergency Management Agency for additional information or questions regarding Tier II reporting.

For more information 

Bucks County Emergency Management Agency
911 Freedom Way
Ivyland, PA 18974
Telephone: (215) 340-8700
Email: buckslepc@buckscounty.org
Office hours: 8:00 A.M. to 5:00 P.M. Monday through Friday