07/01/2026
EPA Simplifies Hazardous Chemical Reporting
Source: Adapted from a Fisher Phillips Insight by Karl F. Kumli and Jamie J. Spataro, July 1, 2026. Fisher Phillips will continue monitoring agency guidance related to this rule and provide updates as additional information becomes available.
The Environmental Protection Agency (EPA) has issued a new Final Rule aligning the agency's Emergency Planning and Community Right-to-Know Act (EPCRA) hazardous chemical inventory reporting requirements with OSHA's 2024 Hazard Communication Standard (HCS). The goal is to reduce confusion and simplify compliance by allowing employers to use the hazard classifications already found on OSHA-compliant Safety Data Sheets (SDSs).
Effective August 21, 2026, employers will have until January 1, 2028, to comply with the new reporting framework.
What Is Changing?
The rule introduces three key updates:
- Hazard categories will now align with OSHA classifications. Employers will be able to use OSHA-compliant SDS hazard categories directly when completing EPCRA reporting, eliminating the need to maintain separate classification systems.
- Tier I and Tier II reporting forms will be updated. EPA will revise reporting forms, definitions, instructions, and electronic reporting systems to reflect the new hazard-category structure.
- Core reporting requirements remain unchanged. Facilities must still submit SDSs or chemical lists when required, file annual Tier II reports by March 1, and continue to comply with applicable reporting thresholds, fees, and state-specific requirements.
Four Steps Employers Should Take Now
Although compliance is not required until 2028, employers should begin preparing by:
- Reviewing current Safety Data Sheets (SDSs) and identifying any classification gaps.
- Updating EPCRA reporting software, workflows, and internal data systems.
- Revising written compliance procedures and retraining employees responsible for hazardous chemical reporting.
- Coordinating with state and local emergency planning agencies to stay informed about reporting system updates and implementation timelines.
Taking these steps now will help ensure a smooth transition while reducing the risk of reporting errors or compliance issues in the future.
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