Due in March: EPCRA Tier II and GHG Emissions Reporting

In Some States, Annual RCRA Reporting Also Due 

Two important environmental reports are due in March—chemical inventory reporting under the Emergency Planning and Community Right-to-Know Act (EPCRA) and greenhouse gas (GHG) emissions reporting under the Clean Air Act. EPCRA “Tier II” reporting is due on March 1. GHG emissions reporting is due by March 31. 

EPCRA Hazardous Chemical Inventory Report
Regulatory Requirement: 40 CFR 370
Report Deadline: March 1

The Emergency Planning and Community Right-to-Know Act (EPCRA) requires facilities that store hazardous chemicals in certain quantities to share information with local and state emergency planning committees and fire departments. This information ensures that emergency personnel know what chemicals are present if they come on site during a natural disaster, chemical release, fire, or other emergency at or around the facility.

For most reportable chemicals, the reporting threshold is 10,000 pounds or more. For Extremely Hazardous Substances (EHS) listed in 40 CFR 355, Appendix A, the reporting threshold is either the Threshold Planning Quantity (TPQ) or 500 pounds, whichever is lower.
 
EPCRA Tier I/II reporting requirements also differ by State. Examples include States listing a wider range of reportable substances, imposing lower reporting thresholds, or assessing a filing fee. There are two forms, a Tier I Form and a Tier II Form. Generally, local emergency responders and state regulations dictate which form(s) facilities must submit. Most facilities submit the Tier II.

More: 
[EPA Website] Tier I Forms and Instructions
[EPA Website] Tier II Forms and Instructions 
[EPA Website] Tier II Reporting Requirements by State

Greenhouse Gas (GHG) Emission Reporting Program
Regulatory Requirement: 40 CFR 98
Report Deadline: March 31

US EPA requires annual greenhouse gas emissions reporting from facilities in certain stationary source categories, fuel and gas suppliers, and carbon dioxide (CO₂) injection sites. Covered facilities must electronically submit information detailing their greenhouse gas emissions output during the previous calendar year. Details required in GHG reporting include specific identifying information about the facility, calculated aggregate annual emissions, and annual GHG emissions by source. 

The GHG Emissions Reporting Program (GHGRP) requirement covers carbon dioxide, methane, nitrous oxide, various hydrofluorocarbons, and other emissions. Each listed substance is assigned a global warming potential (GWP) in 49 CFR Part 98 that reporting facilities to calculate their emissions' impact on the environment (compared to carbon dioxide). 

EPA is presenting two webinars on GHG reporting soon: An introduction to the electronic reporting tools on February 27 and a training on submissions under GHGRP Subpart W (for the oil and gas sector) on March 4.

More: 
[EPA Website] Greenhouse Gas Reporting Program (GHGRP) 
[EPA Website] EPA GHG Reporting Tool  

State RCRA Hazardous Waste Reporting

Under the RCRA hazardous waste regulations, US EPA requires hazardous waste generators to submit a biennial report of their activities by March 1 of every even numbered year. Because 2025 is not an even numbered year, no report is due under the Federal regulations. 

However, many State environmental agencies impose requirements that are more stringent than the Federal RCRA rules, including a requirement for generators to submit annual reports. Generators in all size categories must be familiar with State regulations to fully meet their reporting responsibilities. 

Upcoming Environmental Training

Join an experienced Lion instructor for live training to simplify compliance with EPA air, water, chemical, and hazardous waste programs.  

March 10–11
RCRA Hazardous Waste Management Training
Two days of expert-led training to identify, store, and properly dispose of  your site's hazardous waste under recently updated Resource Conservation and Recovery Act (RCRA) regulations. 

March 13–14
Complete Environmental Regulations Training
Join us to gain a clear view of your facility's environmental responsibilities under the Clean Air Act, Clean Water Act, EPCRA and CERCLA/Superfund, TSCA, FIFRA, and more.