Annual Inventory

Employers must maintain an SDS for any hazardous chemical stored or used in the workplace per OSHA regulations. Under EPCRA Section 311, employers must submit copies of a hazardous chemical SDS to the LEPC, SERC, and local fire department. They must also submit an annual inventory report for that chemical. The inventory report, which is called a Tier II report, must be submitted to the LEPC, SERC, and local fire department by March 1 of each year.

Note that EPCRA requirements do not apply to materials being transported. Therefore, materials being distributed or stored under active shipping papers would not be included in a facility threshold determination under EPCRA Sections 311 and 312. However, spill reporting requirements under Section 304 still apply to all materials, whether in transit or not.

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