EPA Aligns EPCRA Reporting with OSHA HazCom 2024

Why This Update Matters

For years, facilities have had to navigate an awkward disconnect between OSHA’s Hazard Communication Standard (HazCom) and EPA’s Emergency Planning and Community Right-to-Know Act (EPCRA) reporting requirements. Safety Data Sheets (SDSs) would classify hazards one way, while Tier II reporting often required facilities to translate those hazards into different EPA reporting categories.

That extra step has finally been addressed.

On June 22, 2026, the U.S. Environmental Protection Agency published its final rule updating 40 CFR Part 370 to align EPCRA hazardous chemical inventory reporting with OSHA’s 2024 Hazard Communication Standard. While the rule doesn’t create new reporting obligations, it significantly changes how facilities report hazard information and eliminates years of unnecessary interpretation.

Why EPA Changed the Rule

Historically, facilities had to review an SDS, determine the OSHA hazard classifications, and then manually map those hazards into EPA’s Tier II reporting categories.

That process wasn’t always straightforward.

As OSHA adopted newer editions of the Globally Harmonized System (GHS), additional hazard classes were introduced that simply didn’t fit into EPA’s existing reporting structure. EPA recognized that continuing to require this “translation” created unnecessary burden and the potential for inconsistent reporting.

OSHA Hazard Classifications Will Now Be Used Directly

The cornerstone of this rule is simple: EPA will now use OSHA’s hazard classes and hazard categories directly.

Instead of converting SDS information into broader EPCRA categories, facilities will report the hazard classifications exactly as they appear in Section 2 of the Safety Data Sheet.

This is one of those rare regulatory changes that actually simplifies compliance.

New Hazard Classes Added to EPCRA Reporting

Several important OSHA hazard classes are now incorporated directly into EPCRA reporting.

Some of the more notable additions include:

Aerosols
Chemicals Under Pressure
Desensitized Explosives
Chemically Unstable Flammable Gases
Expanded Acute Toxicity categories
Separate reporting for inhalation hazards by gases, vapors, and dusts/mists
More detailed carcinogenicity, reproductive toxicity, skin corrosion, and eye damage categories

The result is a much more detailed hazard profile for emergency planners and first responders.

Goodbye “MSDS”

One of the simplest—but overdue—changes is the removal of the term Material Safety Data Sheet (MSDS) throughout Part 370.

The regulation now consistently uses the term “Safety Data Sheet” (SDS) to match OSHA terminology. EPA also revised the regulatory definition of SDS and removed references to MSDS throughout the rule. It’s a small change, but it eliminates another inconsistency between agencies.

Key Compliance Dates

There are two dates to remember:

Rule Effective Date: August 21, 2026
New Hazard Category Compliance Date: January 1, 2028

Facilities will begin using the revised hazard categories for 2027 inventory data, with reports due by March 1, 2028.

What Facilities Should Do Now

If your organization manages hazardous chemicals or assists customers with EPCRA reporting, now is the time to understand these changes and begin preparing well before the 2028 compliance deadline. Reach out anytime—we’ll make bilingual compliance simple, accurate, and stress-free. Call ICC today at 888.442.9628 (USA) or 888.977.4834 (Canada) or send us an email.