It’s March Chemical and Safety Reporting Time – Again (Sigh)
The month of March represents one of the most intensive compliance windows of the year for chemical and safety reporting, with four major initiatives:
| March 1 | SARA Tier II Inventory | Submit hazardous chemical storage data to SERC, LEPC, and local fire departments. |
| March 1 | RCRA Biennial Report | Only required if your site was a Large Quantity Generator (LQG) in 2025. |
| March 2 | OSHA Form 300A (Electronic) | Submit 2025 Injury/Illness Summary data via the OSHA Injury Tracking Application (ITA). |
| March 31 | EPA GHG Submittal | Required only if emissions exceeded 25,000 metric tons CO2e. |
It’s something you must do, so you go through the motions – reporting hazardous chemicals under SARA Tier II, injuries and illnesses under OSHA, hazardous waste and greenhouse gases under EPA – and you ask yourself, why? Of course, compliance is the number one reason, but what even happens with the data that is submitted, and more importantly, does it even matter?
SARA Tier II is part of the right-to-know law that provides communities with information on chemicals in their neighborhoods and provides first responders with information on the hazards they may encounter when responding to a call. In 2013, the West, Texas fire department responded to a fertilizer storage facility fire without knowing the significant quantity of ammonium nitrate on site. Because the facility had not reported properly under SARA Tier II, fifteen people died in the explosion, including twelve first responders. So yes, this data matters.
It makes sense to proactively look for chemical hazards, but what about OSHA 300 logs, since those injuries and illnesses have already occurred? The data from these logs is used by OSHA, employers, employees and the public to inform worker health and safety decisions. OSHA identifies workplaces that are high hazard, based on days away, restricted or transferred. They target these facilities for unannounced inspections, find evidence of employer knowledge or a particular hazard, and trend the data to determine where new safety standards are needed. The ergonomic and heat stress initiatives came out of the analysis of this data. Employers track the data to look for clusters that may indicate the need for more training or different equipment, and they can use the Total Recordable Incident Rate (TRIR) to benchmark against their industry competitors. By requiring posting of the data, OSHA makes sure that the employees are aware of hazards, and unions can use the information to negotiate for better protections. Even the public can access the data to see a company’s safety history.
On the environmental site, the EPA’s biennial report (annual for some states) helps the agency predict the needed volume of waste management facilities and trend whether their regulations are helping to minimize waste generation or if disposal methods are shifting to other media (landfilling, incineration, wastewater discharge, air emissions) or recycling. Fees are assessed based on quantities of hazardous waste, so facilities are incentivized to reduce the amount of hazardous waste generated. This information is available to the public to track the environmental footprint of facilities as well.
Likewise, the EPA Greenhouse Gas Reporting Program tracks large emitters in a national inventory. In addition to shaping climate policy, this data is used for IRS tax credit verification for clean energy and to support regulations for hydrofluorocarbon phase-out. Businesses can benchmark their performance against other similar organizations, and use the metrics to drive environmental performance, which also means improves financial performance. Non-governmental organizations (NGOs) and investors use the data in decision-making processes, and the public can map emitters in their locale through the Facility Level Information on Greenhouse Gases Tool.
So next time you’re going through the motions, know that data integrity matters, and your data is used to inform real-world decisions that affect our communities, responders, and the safety of our workers. And while you’re at it, consider software that can make the process a whole lot easier.
Chemical Safety’s Environmental Management Systems (EMS) software acts as a central data hub that automates the complex calculations and formatting required for these key requirements (think data integrity and streamlining).
SARA Tier II (Due March 1)
The Environmental Regulatory Reporting Management tool eliminates the “manual lookup” phase by linking your real-time chemical inventory directly to a database of Safety Data Sheets (SDS):
- Threshold Calculations: EMS automatically cross-references your current stock levels against federal and state-specific Threshold Planning Quantities (TPQ) to identify which chemicals must be reported.
- Electronic Filing: It generates correctly formatted electronic files that can be directly uploaded to the EPA’s Tier2 Submit software or state-specific portals.
- Hazard Mapping: The system automatically maps SDS hazard data to the required GHS-aligned hazard categories for the report.
RCRA Biennial Report (Due March 1)
The “Cradle-to-Grave” life cycle of every drum or container of waste is tracked through the Hazardous Waste Management tool:
- Automated GM Forms: It compiles generation and management (GM) data into federally approved reporting formats.
- LQG Monitoring: It continuously monitors your generator status, alerting you if you hit Large Quantity Generator (LQG) levels that trigger the biennial filing requirement.
OSHA Electronic Submittal (Due March 2)
EMS includes a purpose-built Accident & Incident Tracking module designed specifically for OSHA compliance.
- Log Generation: It automatically populates OSHA Forms 300, 300A, and 301 based on incidents recorded throughout the year.
- ITA Integration: The software formats the summary data for direct submission to the OSHA Injury Tracking Application (ITA).
EPA Greenhouse Gas (GHG) (Due March 31)
While many sites report manually, ChemicalSafety.com includes Environmental Regulatory Reporting tools that can track fuel consumption and stationary combustion data.
- Emission Tracking: It assists in calculating CO2e totals to determine if you exceed the 25,000 metric ton threshold for the year.
- Ad-Hoc Reporting: You can schedule custom reports to run at specific intervals to ensure you are trending toward compliance well before the March deadline.
It’s not too late to digitize your 2026 EHS data with Chemical Safety Software. Schedule a demo now.
