Hazardous Chemical Reporting Compliance: EPCRA, Tier II, And Community Right To Know

Inventory data is also a promise to your neighbors

When you think about inventory, you probably think about turns and stockouts. Regulators and first responders see something else in the same numbers. They see tanks, drums, totes, and cartons full of chemicals that could make their lives very hard if something goes wrong. Hazardous chemical reporting compliance is how you turn that private picture into public safety intelligence.

Under the Emergency Planning and Community Right To Know Act, or EPCRA, EPA requires certain facilities to report hazardous chemical inventories when they exceed specific thresholds. The rules live mainly in 40 CFR Parts 355 and 370. Those reports help state and local agencies understand what hazards exist in their jurisdictions so they can plan for emergencies.

When products turn from goods into reportable chemicals

Many consumer products do not look like hazardous chemicals until you store them in bulk. Director of Vendor Operations Kay Hillmann sees this daily. "We are certified in all hazardous materials. We were looking at a matches company, that is a hazardous material. We ship concrete sealant, that is hazardous, a different classification. Paint, your everyday paint you get from a home center, that is hazardous material. Flammables, like gas power generators, that is hazardous material. Perfumes, alcohol."

Those products fall into hazard classes that trigger reporting when volumes grow. Ten thousand pounds of a hazardous chemical is a common threshold for Tier II reports under 40 CFR Part 370, although extremely hazardous substances may require reporting at much lower levels. A busy 3PL can cross these thresholds without noticing if its systems are not watching closely.

OSHA HazCom as the backbone of reporting

OSHA's Hazard Communication Standard in 29 CFR 1910.1200 requires employers to maintain a list of hazardous chemicals in the workplace and to keep Safety Data Sheets. That list becomes the starting point for EPCRA reporting. If you do not know which products in your warehouse meet OSHA's definition of a hazardous chemical, you cannot comply with state and local reporting laws.

Director of Operations and Projects Maureen Milligan explains why employee insight matters. "Just because you happen to work in a warehouse does not mean that your idea is not valid." Employees who work with these materials often notice classification errors, bad labels, or storage drift before managers do. That feedback helps keep reporting accurate.

How fire codes and EPCRA overlap

Local fire departments use EPCRA Tier II reports during pre incident planning. Fire code rules based on the International Fire Code set maximum allowable quantities of flammable and combustible materials per control area. If your EPCRA data does not match what firefighters see on a walkthrough, they will find the gap quickly.

Chief Revenue Officer John Pistone points out that certain goods create more serious planning concerns. "If you have a lithium ion battery that is greater than 300 watt hours, it is considered fully regulated. That means there is special packaging that it has to have. Everybody who touches it has to be certified. You have specific requirements in your warehouses, like the type of sprinkler systems."

Why WMS accuracy decides whether reporting is correct

CTO and COO Bryan Wright puts it simply. "A bad WMS system will not track inventory 100 percent, as it should. A good WMS tracks inventory through the warehouse at every point that you touch it." For hazardous chemical reporting, the WMS must store hazard attributes and break inventory down by area so you can align with fire code control areas and reporting zones.

When hazard codes and quantities live in the item master and update with each move, you can calculate maximum and average on site amounts for EPCRA reporting directly from the system. That eliminates guesswork and panic during reporting season.

Internal audits that prevent reporting surprises

Director of Operations Holly Woods spends much of her time preparing for peak season. "We have very intensive planning as we get close to a peak timeframe. We run forecast models, staffing models, and we audit inventory, equipment. All of these preparations happen ahead of season just to ensure that we can handle anything that comes our way."

Those same audits help verify that physical inventory matches system data and that chemical storage is still compliant with fire code and EPCRA assumptions. Without those checks, a seasonal spike could quietly push a facility into a higher reporting tier without anyone noticing.

Training and culture support accurate reporting

Hazmat employee training under 49 CFR 172.700 through 172.704 creates the foundation for safe handling and documentation. Kay puts it simply. "We have been certified by the expert in the country on hazardous materials in all classifications." When employees understand classification, storage rules, and spill response, they help prevent the mistakes that lead to reporting errors.

Maureen's ground up culture reinforces that. When employees feel heard, they are more likely to raise concerns about mislabeled pallets, strange product concentrations, or outdated SDS data before reporting deadlines arrive.

Why retailers care about EPCRA even if they do not mention it

Retailers and carriers do not usually ask for Tier II reports, but they care deeply about supply chain stability. A citation or shutdown tied to chemical mismanagement can disrupt fulfillment and damage brands. VP of Customer Experience Joel Malmquist explains how he thinks about growth. "With an up and coming business, I am going to ask you questions. What channels are you trying to get into. How do you see your business growing. How can we help you get there."

When higher risk chemicals enter the picture, clean reporting is part of that support. It reassures partners that your operation can handle the risks that come with scale.

Questions founders should ask about chemical reporting

Ask how your 3PL determines whether your products trigger EPCRA thresholds. Ask how hazard data enters the WMS and how internal audits validate it. Ask who owns Tier II reporting and how they coordinate with local fire officials. If those answers sound vague, reporting risk is close.

Turning reporting into a sign of maturity

Hazardous chemical reporting does not have to be stressful. When hazard data, storage rules, training, and culture align, EPCRA compliance becomes a routine reflection of how your operation already works. It also becomes a quiet badge of maturity that retailers, carriers, and regulators notice.

Kay sums up the mindset. "We follow regulations and guidelines to a T because we want to make sure that we are doing it legally, correctly, and safely." Applied to hazardous chemical reporting, that mindset turns inventory data into a safety tool instead of a liability.

If your shelves are filling with more chemical risk, or if reporting thresholds are getting closer, talk with G10 about how to build a reporting process that protects your people, your community, and your growth.