Tier II reporting is about to look very different. In our recent webinar, Tier II Is Changing: What the GHS Shift Means for Compliance Teams, more than 120 EHS professionals joined us to talk through the new rule. Presenters included Encamp CEO and Co-founder Luke Jacobs and Technical Program Manager Madison Roe. Before joining Encamp, Madison managed Indiana’s SARA Title III program.
This post answers the most common questions from the session. Plus, we wrap up with practical steps you can take now to stay ahead of the change.
Key Takeaways
- EPA is replacing the 24 broad EPCRA hazard categories with the 118 OSHA hazard categories found on your safety data sheets (SDSs).
- The federal compliance date is January 1, 2028. That means your reporting year (RY) 2027 Tier II report, due March 1, 2028, is the first one affected.
- Missouri has already switched its portal to the new categories, and Oregon is updating ahead of schedule as well.
- Your SDSs are the source of truth. EPA’s crosswalk is a helpful starting point, but it can’t replace a review of each SDS.
- The best time to prepare is now, before Tier II season begins and regulators get busy.
What Is the Tier II GHS Change?
EPA published a final rule on June 22, 2026, that changes how facilities classify chemical hazards on Tier II reports. The rule replaces the 24 EPCRA hazard categories with the 118 hazard classes and categories defined in OSHA’s Hazard Communication Standard. These are the same classifications listed in Section 2 of your SDSs.
Think of it like moving from a few big storage bins to a labeled drawer system. Under the old approach, you had to take the specific hazards on your SDS and sort them into broader EPCRA buckets. Under the new rule, you report the hazard category exactly as it appears on the SDS.
GHS stands for the Globally Harmonized System of Classification and Labelling of Chemicals. It’s the international standard that OSHA’s hazard communication rules follow.
Why is the EPA Making This Change?
EPA wants Tier II reporting to line up with OSHA’s standards, so both agencies speak the same language. This alignment also removes a translation step that often led to reporting errors.
“It sounds like a crazy change, but it’s actually a good change,” Madison said during the webinar. “It takes something that was very broad and makes it more granular. It makes more sense.”
More detailed hazard data also helps the people who use your reports. First responders get a clearer picture of what’s on-site. Regulators can better understand your inventory. For example, they can tell whether sulfuric acid is contained in a battery or stored in chemical form.
This isn’t the first time EPA has aligned Tier II with OSHA. The agency made a similar, smaller update in 2016, when it adopted OSHA’s hazard classes but not the more detailed categories.
When Does the New Tier II Hazard Classification Take Effect?
The federal compliance date is January 1, 2028. Here’s what that means for your filings:
- RY2026 report (due March 1, 2027): Uses the current hazard categories in most states.
- RY2027 report (due March 1, 2028): The first report that requires the new OSHA hazard categories nationwide.
States must meet this federal minimum, but they can move faster or add their own requirements. That’s why it’s important to watch your state’s announcements closely.
Which States Are Adopting the New Hazard Categories Early?
Missouri and Oregon are moving ahead of the federal timeline. So far, no other states have announced plans to follow.
Missouri converted its reporting portal to the new categories on July 16, 2026. If you file in Missouri, you’ll see the new categories when you submit this season. Missouri hasn’t posted this change on its main website. The state has mainly shared it through account holders and its email list, so many facilities may not know about it yet.
Oregon is also updating early, but its approach is different. The state manages SDS data internally and will apply the new categories for you. You won’t need to change anything yourself. Your report will still look different, though, because it will show many more hazard categories than before. Oregon also noted that its chemical catalog is large, so some updates may not appear until RY2027.
Can I Use the EPA Crosswalk to Map My Hazard Categories?
You can use it as a starting point, but you shouldn’t rely on it alone. EPA published a crosswalk file that links the old EPCRA categories to the new OSHA categories. Even the EPA describes it as a starting point rather than a substitute for checking your SDSs.
The reason is that the mapping runs one-to-many. A single old EPCRA category can split into several more specific OSHA categories. The crosswalk can’t tell you which ones apply to a given chemical. Only the SDS can.
“Going from the safety data sheet as the source of truth is going to be the most surefire way for companies to move forward,” Luke said.
How Current Do My Safety Data Sheets Need to Be?
Use the most recent SDS available for each chemical. Ideally, that’s a version updated for OSHA’s 2024 Hazard Communication Standard.
“If you can get a 2024 SDS for the chemical you’re working with, that’s probably the best way,” Madison said. As a general rule, avoid using any SDS dated before 2016.
Will States Require SDS Uploads With Tier II Reports?
The new rule doesn’t require it, and as of now, no state has added it as part of this change. Some states already ask for SDSs with Tier II submissions, including Illinois.
That could change over time. Hazard categories will now come straight from the SDS, so some states may decide to request a copy with each report. “I could see that happening in the next couple of years,” Luke said. Keeping your SDS library complete and organized now will put you in a strong position if that happens.
How Will This Change Affect State Regulators?
Regulators are learning the new rule at the same time you are, and most work on very small teams. “We see staff for regulators from one person to maybe up to five, but not much more than that,” Madison said.
During this transition, state agencies will need to update their portals, forms, and guidance documents. They’ll also field more questions than usual. That means slower response times, especially once Tier II season starts on January 1.
Madison’s advice from her time as a regulator is to reach out early. Review your SDSs now, note which chemicals and hazards will change, and send your questions before the rush.
How to Prepare for the Tier II GHS Shift
The federal deadline gives you about 18 months, which is a rare chance to get ahead of a regulatory change. “The more proactive teams are, the easier it is for them to deal with changes like this,” Luke said. “If you wait until the reporting season, there’s more risk that it becomes a fire drill.”
Here are four steps to take now.
1. Collect Every Safety Data Sheet
Make sure you have a current SDS for every reportable chemical at every facility. Many companies discover gaps once they start looking. Request updated versions from your suppliers wherever you’re missing SDSs or have outdated ones.
2. Re-Derive Hazard Categories From the Source
Use each SDS to identify the correct OSHA hazard categories. You can use EPA’s crosswalk as a guide. When the two disagree, follow the SDS.
3. Contact Your Regulators Before Tier II Season
Prepare your questions early and send them before January 1. You’ll get faster, clearer answers than you will in February.
4. Watch for State Announcements
Missouri shows that states can move quickly and quietly. Sign up for your state emergency response commission’s email list, check its portal regularly, and look out for new forms and guidance.
How Encamp Is Helping Customers Through the Transition
Encamp tracks regulatory changes at the state and federal levels and builds direct relationships with regulators. We update our compliance engine and software as rules change, so customers stay compliant without starting from scratch.
For this change, we’re mapping the new hazard categories for the SDSs already in our customers’ inventories. Missouri customers will see the updated view starting in October. Encamp is also the largest third-party filer of Tier II reports in the U.S., with more than 24,000 reports filed last Q1.
Want to see what this looks like in practice? Read how WSI Supply Chain Solutions freed up 700+ hours of Tier II work each year.
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