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At the end of June, the U.S. Environmental Protection Agency (EPA) announced a final rule updating the agency’s current hazardous chemical inventory reporting requirements. Specifically, the rule aligns those requirements, which are housed under the Emergency Planning and Community Right-to-Know Act (EPCRA), with the Occupational Safety and Health Administration's (OSHA’s) Hazard Communication Standard (HCS). Explicitly, according to the EPA, the changes will reduce confusion and increase understanding by regulated employers. Previously, OSHA released a new workplace job safety and health notice to inform workers about their rights under the Occupational Safety and Health (OSH) Act. Such updates allow the agency to better inform businesses and their employees about workplace hazards.
Overview of the Hazard Communication Standard
To ensure chemical safety in the workplace, information about possible chemical hazards must be available and understandable to workers. OSHA’s HCS requires the development and dissemination of that information:
- Chemical manufacturers and importers must evaluate the hazards of the chemicals they produce or import. They must also prepare labels and safety data sheets (SDSs) to convey the hazard information to their downstream customers.
- All employers with hazardous chemicals in their workplaces must have labels and SDSs for exposed workers. Those workers must be trained on how to handle the chemicals appropriately.
Previously, the HCS underwent two major revisions. Firstly, in 2012, the standard was aligned with the third revision of the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (GHS). The update was made to provide a common and coherent approach to classifying chemicals and communicating hazard information globally.
Secondly, in 2024, the HCS was updated to align primarily with the seventh revision of the United Nations’ GHS. In particular, the updated standard requires labels on small packaging to be more comprehensive and readable. The updates also ensure trade secrets no longer prevent workers and first responders from receiving critical hazard information on SDSs.
Additionally, workers benefited from other changes, including:
- updated physical hazard classes to better inform about the safe handling of explosives, aerosols, and chemicals under pressure; and
- revised precautionary statements on safely handling, storing, and disposing of hazardous chemicals.
Why Is the EPA Changing the Hazardous Chemical Inventory Reporting Requirements?
Overall, the EPA is updating the hazardous chemical inventory reporting regulations in one major way. This includes instituting hazard categories that are both:
- used within EPCRA reporting and
- correspond to the hazard classifications appearing on OSHA-compliant safety data sheets (SDSs).
As touched upon earlier, the EPA’s stated objective is to reduce confusion. This includes reducing the administrative burden on regulated facilities, state and local emergency planning entities, fire departments, and first responders. However, even though those industries are specifically called out, any business that produces, uses, or stores hazardous chemicals must comply with the EPCRA and these updates. Such changes will allow hazard information to flow more directly from SDSs into EPCRA inventory forms. The rule also replaces outdated material safety data sheets (MSDSs) terminology with SDSs terminology and makes related definitional and form revisions.
What Are the Main Changes to the Hazardous Chemical Inventory Reporting Requirements?
According to the EPA’s final rule, there are two main updates to EPCRA hazardous chemical reporting:
- As mentioned, the EPCRA hazardous chemical categories will now align with the HCS hazard categories, as explained on safety data sheets.
- Hazardous chemical inventory reporting forms will now be updated to include chemical applicability, definitions, SDS list submissions, inventory reporting, form contents, and instructions.
- Core reporting duties will not change based on this update. For example, affected businesses must still submit SDSs, chemical lists, and annual hazardous chemical inventory reports as required under the EPCRA.
Employer Takeaways
In conclusion, as noted earlier, the latest updates to the EPCRA’s hazardous chemical inventory reporting requirements will affect workplaces that currently house or use chemicals. All employers who must comply with that regulation should review the final rule and prepare for any changes. Such changes could include reviewing your current safety data sheets inventory and identifying any gaps. Also, hazardous chemical reporting workflows may need to be examined and restructured. The EPA’s final rule takes effect on August 21st, 2026, with a compliance date of January 1st, 2028.
