The U.S. Environmental Protection Agency has finalized a rule that meaningfully reshapes how facilities classify and report hazardous chemicals under the Emergency Planning and Community Right-to-Know Act (EPCRA). Published on June 22, 2026, the rule conforms the hazardous chemical inventory reporting requirements of EPCRA Sections 311 and 312 to the Occupational Safety and Health Administration's Hazard Communication Standard, incorporating the amendments OSHA adopted in 2012 and 2024. For facilities already subject to community right-to-know obligations, the change represents a substantive recalibration of the hazard framework, not a simple administrative refresh.
At the core of the rule, EPA directly incorporates OSHA's hazard classes and categories as the EPCRA hazard categories used for Section 311 list submissions and Section 312 Tier II inventory reporting. This alignment is designed to reduce inconsistencies between workplace hazard communication and community right-to-know disclosures, allowing facilities to rely on a single, unified classification system across both regulatory regimes. In practice, however, it means that facilities must revisit how their covered chemicals are characterized and ensure that the categories used for EPCRA reporting reflect the updated OSHA framework.
The rule also retires the existing flammable aerosols hazard class and replaces it with two new classes: aerosols and chemicals under pressure. Facilities that manage aerosolized products, compressed materials, or pressurized formulations should anticipate reclassification of certain substances and corresponding adjustments to internal inventories and reporting templates.
The rule becomes effective August 21, 2026. Regulated entities must use the updated hazard categories for EPCRA Section 311 list submissions by January 1, 2028, providing a defined compliance window to update Safety Data Sheet review procedures, revise inventory reporting workflows, coordinate with environmental, health, and safety personnel, and adjust Tier II filing practices. Facilities with multiple locations or complex chemical portfolios should consider initiating classification reviews well in advance of the deadline to identify substances that may shift categories under the new framework.
Noncompliance with EPCRA reporting obligations can carry significant federal enforcement exposure, and the transition to the aligned framework introduces additional opportunities for classification errors. Facilities should plan accordingly and document classification decisions with care.
This update is provided for general informational purposes and does not constitute legal advice. Clients with specific reporting obligations or classification questions should consult counsel for tailored guidance.