Tier II reporting is moving from about 23 broad hazard categories to 118 pulled straight from the SDS. This checklist helps you find your reconciliation gap.
If you report hazardous chemicals under Tier II, this change touches every facility on your list. The new categories aren’t a simple find-and-replace. Most teams will need to check their inventory chemical by chemical, and that takes time you don’t have to spare right before a deadline.
This checklist walks you through five steps to size up your gap and get ahead of it:
- Confirm your inventory baseline.
- Check your SDS coverage (this number is your real reconciliation gap).
- Spot the hazard classes most likely to trip you up, like aerosols and chemicals under pressure.
- Know your filing timeline, including a Missouri-specific deadline that lands a full year early.
- Decide how your team will reconcile the data.
You’ll also get a quick-math worksheet to estimate your gap in minutes, no full audit required.
Who It’s For
This checklist is built for EHS and compliance teams preparing for the shift to GHS-aligned Tier II categories, especially anyone filing in Missouri, where the new categories apply a full year ahead of the federal deadline. It’s also a fit for multi-facility teams who need a consistent way to size up their reconciliation gap before assigning the work.
Last Updated: September, 2026.
