Four Calendars, Not One: The Recurring EHS Deadlines a Manufacturing Facility Owes
A manufacturing plant does not owe one list of dates. It owes four, on four different clocks. Here is every recurring federal obligation with its CFR citation.
The greenhouse gas reporting deadline for reporting year 2025 has now carried three different dates in nine months. The EPCRA Tier II deadline has carried one. Both of those were true on the same morning, and the gap between them is why a facility cannot run its environmental and safety obligations off a single list of dates taped inside a cabinet door.
A manufacturing plant does not owe one compliance calendar. It owes four, and they run on four different clocks. Some dates are fixed in statute and no agency can move them. Some are set by rule and move when the Federal Register says so. Some exist only inside a permit. And some have no date at all.
What follows is the recurring federal layer, month by month, with the CFR citation for each obligation and a plain statement of who owes it. Everything year-specific sits in one section near the bottom, under What Changed This Year. That split is deliberate. Eight-tenths of this calendar reads the same in eCFR today as it did a year ago, and the moving parts are easier to maintain when they are in one place.
Four Calendars, Not One
Calendar one: the statutory dates
EPCRA Tier II is due March 1 and the TRI Form R is due July 1. Both dates come from statute and are codified at 40 CFR 370.45(a) and 40 CFR 372.30(d). EPA states on its own Tier II page that it cannot grant extensions. No agency memo, shutdown or reconsideration proposal changes either date, which is the practical reason these two filings get the strictest internal treatment at most plants.
Calendar two: the rule-based dates
The OSHA Form 300A posting window of February 1 through April 30 (29 CFR 1904.32(b)(6)) and the March 2 electronic submission (29 CFR 1904.41(c)) are set by rule. So is the Greenhouse Gas Reporting Program deadline at 40 CFR 98.3(b)(6), which is exactly why that one has moved three times in nine months while Tier II sat still. Rule-based dates are real deadlines. They are just revisable by a document you have to actually read.
Calendar three: the permit-driven dates
Title V annual compliance certifications and semiannual monitoring reports (40 CFR 70.6(c)(5)(i) and 70.6(a)(3)(iii)(A)), NPDES discharge monitoring reports (40 CFR 122.41(l)(4)) and industrial stormwater benchmark monitoring run on the dates written into the facility’s own permit. No published calendar can supply these. The only honest instruction is to build them from the permit portfolio, permit by permit, and then put them on the same page as the federal dates.
Calendar four: the anniversary intervals
Respirator fit testing (29 CFR 1910.134(f)(2)), audiograms (29 CFR 1910.95(g)(6)), the lockout/tagout periodic inspection (29 CFR 1910.147(c)(6)(i)), DOT hazmat recurrent training every three years (49 CFR 172.704(c)(2)), the five-year SPCC plan review (40 CFR 112.5(b)) and the five-year RMP resubmission (40 CFR 68.190(b)(1)) have no calendar date whatsoever. They are due on the anniversary of the last one, per employee or per plan. This is the category that lapses, because nothing arrives in the mail to prompt it and no portal sends a confirmation email when it does not happen.
Keep those four buckets in mind while reading the tables below. A facility that tags every obligation with which clock it runs on can answer the only question that matters in February: is this date negotiable, and who is supposed to be watching it.
The Recurring Compliance Calendar, Month by Month
Forty-one recurring federal obligations, split by which clock each one runs on. Every row carries a citation and either a date or an interval. Nothing in these three tables is year-specific, which is why this part of the page does not need rewriting every January.
Fixed calendar dates
| Month | Obligation | Citation | Who Owes It |
|---|---|---|---|
| January, by the 30th | Industrial stormwater MSGP Annual Report, filed through NeT-MSGP | 2021 MSGP Part 7.4; NPDES authority under 40 CFR 122 | Any facility with EPA MSGP coverage in one of the 29 covered industrial sectors |
| January, year-end task | Review the OSHA 300 Log for completeness and accuracy, correct errors, prepare and certify the annual summary | 29 CFR 1904.32(a), certification by a company executive per 1904.32(b)(3) and (b)(4) | Every establishment required to keep Part 1904 records |
| January, with the first shipment | EPCRA 313 supplier notification to each recipient of each covered mixture or trade name product | 40 CFR 372.45(a) and (c) | Facilities in SIC 20 through 39, or the NAICS equivalent, that manufacture, import or process a listed toxic chemical and sell or distribute it in a mixture |
| February 1 | Post the OSHA Form 300A annual summary in a conspicuous place at each establishment | 29 CFR 1904.32(b)(5) and (b)(6) | Every establishment required to keep Part 1904 records, including those with no recordable cases |
| March 1 | EPCRA Tier II hazardous chemical inventory to the SERC, the LEPC and the local fire department | 40 CFR 370.45(a); thresholds at 40 CFR 370.10 | Any facility required to keep an SDS that stored a hazardous chemical at or above threshold at any time in the prior year |
| March 1, even years | RCRA Biennial Report on EPA Form 8700-13 A/B, covering the prior odd-numbered reporting year | 40 CFR 262.41(a) and (b) | Anyone who was a large quantity generator for at least one month of the odd-numbered reporting year and shipped waste off site, plus LQGs who treat, store or dispose on site |
| March 1, even years | LQG re-notification on EPA Form 8700-12, which may be submitted as part of the Biennial Report | 40 CFR 262.18(d) | Large quantity generators |
| March 2 | Electronic submission of the prior calendar year’s injury and illness records through the Injury Tracking Application | 29 CFR 1904.41(c) | The three establishment tiers in 1904.41(a) |
| April 30 | Last day the Form 300A posting must remain up | 29 CFR 1904.32(b)(6) | Same as the February 1 posting |
| July 1 | TRI Form R or Form A for the prior reporting year, filed through TRI-MEweb | 40 CFR 372.30(d); thresholds at 40 CFR 372.25 | Covered-NAICS facilities with 10 or more full-time-equivalent employees that exceeded an activity threshold for a listed chemical |
| July 1 | PCB annual document log prepared for the facility covering the previous January through December. Prepared and kept on site, not submitted to EPA | 40 CFR 761.180(a) | Facilities using or storing at least 45 kg of PCBs in PCB Containers, or one or more PCB Transformers, or 50 or more large PCB Capacitors |
| Before July 1 | PHMSA hazmat registration renewal for the July 1 to June 30 registration year. Carry the certificate | 49 CFR 107 subpart G | Hazmat offerors and transporters in registration-triggering categories |
| September 1, every four years from 2021, next in 2029 | SQG re-notification on EPA Form 8700-12 | 40 CFR 262.18(d) | Small quantity generators |
Permit-driven dates, built from the permit rather than from a calendar
| Interval | Obligation | Citation | Who Owes It |
|---|---|---|---|
| At least every 6 months | Title V monitoring report. The permit must require reports of any required monitoring at least every 6 months | 40 CFR 70.6(a)(3)(iii)(A) | Part 70 major sources |
| Not less than annually | Title V compliance certification. The permit specifies the frequency, which cannot be less often than annually | 40 CFR 70.6(c)(5)(i) | Part 70 major sources |
| At the intervals specified in the permit | NPDES Discharge Monitoring Report, submitted electronically | 40 CFR 122.41(l)(4) | Any NPDES individual or general permittee with monitoring requirements |
| Once per quarter in years 1 and 4 of coverage | MSGP benchmark monitoring, reported within 30 days of receiving full lab results | 2021 MSGP Part 4.2.2 | MSGP-covered facilities in sectors with benchmarks |
| Once per quarter for the whole coverage period | MSGP indicator monitoring for pH, TSS and COD | 2021 MSGP Part 4.2.1.1.a | All MSGP-covered facilities |
| At least quarterly | MSGP routine facility inspection and quarterly visual assessment, documented and kept with the SWPPP | 2021 MSGP Parts 3.1.6 and 3.2.3 | All MSGP-covered facilities |
Anniversary-driven intervals, due on the anniversary of the last one
| Interval | Obligation | Citation | Who Owes It |
|---|---|---|---|
| Annually, per employee | Respirator fit test, required before initial use and at least annually after | 29 CFR 1910.134(f)(2) | Any employer with employees in required respirator use |
| Annually, per employee | Respirator retraining | 29 CFR 1910.134(k)(5) | Same |
| Annually, per employee | New audiogram after the baseline | 29 CFR 1910.95(g)(6) | Employers with employees exposed at or above an 8-hour TWA of 85 dBA |
| Annually, per employee | Hearing conservation training repeated | 29 CFR 1910.95(k)(2) | Same |
| At least annually, per procedure | Periodic inspection of each energy control procedure by an authorized employee not using it, plus a written certification | 29 CFR 1910.147(c)(6)(i) and (c)(6)(ii) | Any employer with lockout/tagout procedures |
| At least annually | Bloodborne pathogens Exposure Control Plan reviewed and updated | 29 CFR 1910.1030(c)(1)(iv) | Employers with occupational exposure to blood or OPIM |
| At least annually, per employee | Bloodborne pathogens training | 29 CFR 1910.1030(g)(2)(ii) | Same |
| Monthly, then annually | Portable fire extinguishers visually inspected monthly, with an annual maintenance check and a retained record | 29 CFR 1910.157(e)(2) and (e)(3) | Employers with portable extinguishers provided for employee use |
| Annually, per employee | Fire extinguisher education and hands-on training repeated | 29 CFR 1910.157(g)(2) and (g)(4) | Same |
| Annually, per employee | HAZWOPER 8-hour refresher training | 29 CFR 1910.120(e)(8) | Employees covered by 1910.120(e)(1) and their managers and supervisors |
| Within 1 year after each entry | Review the permit space program using the canceled permits and revise as necessary | 29 CFR 1910.146(d)(14) | Employers with permit-required confined spaces |
| Annually | LQG facility personnel take part in an annual review of the initial hazardous waste training | 40 CFR 262.17(a)(7)(iii) | Large quantity generators. Initial training is due within six months of employment or assignment per 262.17(a)(7)(ii) |
| Annually | PSM certification that operating procedures are current and accurate | 29 CFR 1910.119(f)(3) | PSM-covered processes |
| At least every 3 years | PSM refresher training | 29 CFR 1910.119(g)(2) | Same |
| At least every 3 years | PSM compliance audit | 29 CFR 1910.119(o)(1) | Same |
| At least every 5 years | PSM process hazard analysis update and revalidation | 29 CFR 1910.119(e)(6) | Same |
| At least once every 3 years, per employee | DOT hazmat recurrent training. Initial training within 90 days of employment or a change in job function per 172.704(c)(1) | 49 CFR 172.704(c)(2) | Every hazmat employer, for every hazmat employee |
| At least once every 3 years, per operator | Powered industrial truck operator performance evaluation | 29 CFR 1910.178(l)(4)(iii) | Any employer with powered industrial trucks |
| At least once every 5 years | SPCC Plan review and evaluation. Amend within six months of the review if warranted, and have a PE certify technical amendments per 112.5(c) | 40 CFR 112.5(b) | Facilities over the 112.1(d)(2) oil storage thresholds |
| At least once every 5 years | RMP update and resubmission | 40 CFR 68.190(b)(1) | Stationary sources with a covered process above a threshold quantity |
| 5 years, rolling | Retain OSHA Forms 300, 300A and 301 | 29 CFR 1904.33 | Every establishment required to keep Part 1904 records |
| 3 years, rolling | Retain hazmat employee training records covering the preceding three years, kept while the person is a hazmat employee and for 90 days after | 49 CFR 172.704(d) | Every hazmat employer |
One note on the hazmat refresher intervals, because they get filed in the wrong place: the two-year IATA interval and the three-year IMDG interval come from the IATA Dangerous Goods Regulations and the IMDG Code. They are not CFR requirements and they are not DOT requirements. Only the three-year interval at 49 CFR 172.704(c)(2) is.
Statutory Dates: The Two That Cannot Move
When are EPCRA Tier II reports due?
March 1 every year, under 40 CFR 370.45(a), which requires submission on or before March 1 of each year after the facility becomes subject to the part. Reports go to the State Emergency Response Commission, the Local Emergency Planning Committee and the local fire department. The date is statutory and EPA states it cannot grant extensions.
The trigger catches more facilities than most plant managers expect, because it is not an industry code. Any facility required to keep a safety data sheet under OSHA’s Hazard Communication Standard that stored a hazardous chemical at or above threshold at any point in the preceding calendar year owes a report. Thresholds sit at 40 CFR 370.10: 10,000 pounds for a hazardous chemical other than an extremely hazardous substance, and 500 pounds or the threshold planning quantity, whichever is lower, for an EHS. Retail gasoline and retail diesel in qualifying underground storage tanks carry separate thresholds of 75,000 and 100,000 gallons.
The federal date does not vary. The filing mechanics do, and that is covered further down under state variations. Build the February work backward from March 1 with the state portal verified first, because a facility that discovers a changed portal on February 26 has created a different problem than the one it thought it had.
When is the TRI Form R due, and what triggers it?
July 1 of the following year, under 40 CFR 372.30(d). The trigger is a covered NAICS code, 10 or more full-time-equivalent employees, and exceeding an activity threshold in 40 CFR 372.25: 25,000 pounds manufactured or processed, or 10,000 pounds otherwise used, for the calendar year.
The Form R sits next to a second EPCRA 313 obligation that almost never appears on a facility calendar. Under 40 CFR 372.45(a) and (c), a supplier notification must go out with at least the first shipment of each covered mixture or trade name product to each recipient in each calendar year. A revised notice goes out with the first shipment after any composition change, and a correction goes out within 30 days of discovering an error. There is no portal and no confirmation, so this one lives or dies on whether someone in shipping knows it exists.
Rule-Based Dates: The OSHA Cycle and the Waste Reports
When must OSHA Form 300A be posted, and when is the electronic submission due?
February 1 through April 30 for the posting, and March 2 for the electronic submission. 29 CFR 1904.32(b)(6) requires the annual summary posted no later than February 1 and kept up until April 30. 29 CFR 1904.41(c) requires covered establishments to submit the prior year’s information electronically by March 2. Missing either is independently citable.
Before either one, the 300 Log has to be closed out. 29 CFR 1904.32(a) requires a review for completeness and accuracy, correction of errors, preparation of the annual summary, and certification. The certification is narrower than most people assume: under 1904.32(b)(4) it has to be signed by the owner in a sole proprietorship or partnership, a corporate officer, the highest-ranking company official working at the establishment, or that official’s immediate supervisor. A safety coordinator’s signature does not satisfy it. Post the 300A even in a year with zero recordable cases.
The two obligations fail in different ways, and that difference is worth building a process around. A missing posting is found in person, usually in the first fifteen minutes of a walkthrough. A missing electronic submission is found without anyone visiting, because OSHA can compare the set of expected filers against the set that actually filed. That asymmetry is why the March 2 date is the one most likely to go unnoticed for a full year. If it is already missed, file anyway. OSHA’s Injury Tracking Application FAQ states the application accepts the prior year’s data through the end of the calendar year, and late filing is still citable. A new safety manager inheriting a recordkeeping program with no history should start with the OSHA compliance walkthrough for a new safety manager.
Which establishments have to submit injury data electronically to OSHA?
Three tiers in 29 CFR 1904.41(a). Establishments with 20 to 249 employees in an Appendix A industry and establishments with 250 or more employees in any recordkeeping industry both submit Form 300A. Establishments with 100 or more employees in an Appendix B industry submit Forms 300 and 301 plus the 300A. Part-time and temporary workers each count as one.
The Appendix B tier is the materially heavier lift, because it requires case-level records rather than a summary. Those records need to be clean before March, not during it. Under 1904.41(b)(2), part-time, seasonal and temporary workers each count as one employee for the headcount, which pulls in plants that run a seasonal second shift and assume they are under the line. A fourth path exists at 1904.41(a)(3): any establishment can be required to submit upon written notification from OSHA.
The Appendix A and Appendix B lists are not static. A NAICS check against the current appendices beats repeating last year’s conclusion, and we-were-not-covered-last-year is the most common wrong answer in this program.
When is the RCRA Biennial Report due and who actually has to file it?
March 1 of each even-numbered year, on EPA Form 8700-13 A/B, under 40 CFR 262.41. It captures anyone who was a large quantity generator for at least one month of the prior odd-numbered reporting year and shipped waste off site. One large cleanout month pulls an otherwise-SQG facility into the filing.
That phrase, for at least one month, is where facilities get caught. The LQG threshold at 40 CFR 260.10 is 1,000 kg of non-acute hazardous waste per calendar month, or more than 1 kg of acute waste, or more than 100 kg of acute spill residue. A plant that ran one tank cleanout in March and crossed 1,000 kg that month files as an LQG for the whole cycle, even if it operated as a small quantity generator the other eleven months. The SQG band runs from over 100 kg to under 1,000 kg per calendar month.
LQGs also owe an annual training review under 40 CFR 262.17(a)(7)(iii), with initial training due within six months of employment or assignment under 262.17(a)(7)(ii). That review has no filing and no portal, which puts it squarely in the fourth calendar.
How often does a hazardous waste generator have to re-notify EPA of its generator status?
Under 40 CFR 262.18(d), large quantity generators re-notify by March 1 of each even-numbered year on EPA Form 8700-12, and may submit it as part of the Biennial Report. Small quantity generators re-notify by September 1, starting in 2021 and every four years after, so the next SQG date is September 1, 2029.
No reminder letter arrives for either one. The LQG version is easy to catch because it rides along with a report that is already on the calendar. The SQG version is the problem: a four-year interval with a September date and no filing package around it is the kind of obligation that outlives the person who last did it. Put the 2029 date in the tracker now, with the form number on it.
Permit-Driven Dates: What Only Your Permit Knows
How often is a Title V annual compliance certification and semiannual monitoring report due?
40 CFR 70.6(c)(5)(i) requires the permit to specify a certification frequency not less than annually. 40 CFR 70.6(a)(3)(iii)(A) requires reports of any required monitoring at least every 6 months. Both actual dates come from the permit rather than from a generic calendar. Applicability is the 40 CFR 70.2 major source definition.
Those thresholds are 100 tons per year or more of any regulated air pollutant, 10 tpy of any single hazardous air pollutant, or 25 tpy of any combination of HAPs, with lower category-specific figures and a 50 tpy VOC figure in ozone transport regions. A facility that sits under all of them has no Title V obligation and no certification to make.
One substantive change took effect October 26, 2026 and it changes what the certification covers. EPA’s final rule at 91 FR 61026 amends 40 CFR parts 70 and 71 to codify when requirements from other Clean Air Act programs count as applicable requirements for Title V purposes. Among other things, it clarifies that the general duty to prevent accidental releases of hazardous substances is not a Title V applicable requirement and is not implemented through Title V. The certification frequency did not change. The set of requirements a facility certifies against did, so the next annual certification should be built against the current applicable-requirement list rather than copied forward from last year’s.
When is the industrial stormwater annual report due?
By January 30, under Part 7.4 of EPA’s 2021 Multi-Sector General Permit, submitted through NeT-MSGP. Benchmark monitoring runs quarterly in years 1 and 4 of coverage, reported within 30 days of receiving full lab results. The 2021 MSGP expired February 28, 2026 and is running on administrative continuance, and the proposed 2026 MSGP has not been issued.
The continuance matters more than it sounds. The 2021 MSGP remains in force and effect for facilities covered before expiration, so the January 30 Annual Report, the quarterly indicator monitoring for pH, TSS and COD, the quarterly routine inspection and the quarterly visual assessment all still apply. EPA proposed the 2026 MSGP in December 2024 under docket EPA-HQ-OW-2024-0481, the comment period closed May 19, 2025, and the replacement has not issued. New coverage mechanics during continuance should be confirmed with the EPA region rather than assumed. In a state with delegated NPDES authority, the EPA permit does not apply at all and the state industrial stormwater general permit does, with its own annual report date and its own benchmark schedule.
Anniversary Intervals: The Deadlines With No Date
How often must an SPCC plan be reviewed and recertified?
At least once every five years, under 40 CFR 112.5(b). If the review identifies field-proven prevention or control technology that would reduce the likelihood of a discharge, the plan must be amended within six months of the review, and a Professional Engineer must certify technical amendments under 112.5(c). Applicability starts at 1,320 gallons aggregate aboveground.
A facility is outside Part 112 only if it meets both thresholds in 40 CFR 112.1(d)(2): aggregate aboveground oil storage capacity of 1,320 US gallons or less, counting only containers of 55 gallons or greater, and completely buried capacity of 42,000 US gallons or less. One 2,000-gallon diesel day tank behind the building puts the whole plant inside the rule. The five-year clock then runs from the date of the last review, which is a date nobody tracks unless somebody decided to track it.
How often does DOT hazmat employee training have to be repeated?
At least once every three years, under 49 CFR 172.704(c)(2). Initial training is due within 90 days after employment or a change in job function under 172.704(c)(1), and until it is complete the employee may work only under direct supervision. Records must cover the preceding three years under 172.704(d).
The definition of hazmat employee is what makes this one a recurring finding. It reaches anyone who signs a shipping paper, loads or unloads, or prepares a package for transport. In practice that is shipping and receiving staff who are usually not in anyone’s training matrix, because the matrix was built around production roles. The records requirement is specific: keep them while the person is a hazmat employee and for 90 days after. Separately, the PHMSA registration year runs July 1 through June 30, so the renewal has to be done before July 1 and the certificate has to be carried.
Which OSHA programs have a hard annual interval with no calendar date?
Respirator fit testing and retraining (29 CFR 1910.134(f)(2) and (k)(5)), audiograms and hearing conservation training (1910.95(g)(6) and (k)(2)), the lockout/tagout periodic inspection with written certification (1910.147(c)(6)), bloodborne pathogens plan review and training (1910.1030(c)(1)(iv) and (g)(2)(ii)), extinguisher maintenance and training (1910.157(e)(3) and (g)(2)), and the HAZWOPER 8-hour refresher (1910.120(e)(8)).
Add the ones with longer intervals and the list gets harder to hold in anyone’s head. The permit space program has to be reviewed within one year after each entry using the canceled permits (1910.146(d)(14)). Powered industrial truck operators need a performance evaluation at least once every three years (1910.178(l)(4)(iii)). PSM-covered processes carry four separate clocks: an annual certification that operating procedures are current and accurate, refresher training at least every three years, a compliance audit at least every three years, and a process hazard analysis revalidation at least every five years (1910.119(f)(3), (g)(2), (o)(1) and (e)(6)).
Here is the pattern worth naming. On a plant walkthrough, the obligations that get done are the ones with a portal and a confirmation email. The lockout/tagout periodic inspection certification is a signed sheet in a binder, and the date on it is often two years old because the authorized employee who used to run it changed roles and nobody inherited the clock. Three of the five standards in OSHA’s preliminary FY2026 top-10 most frequently cited list that touch manufacturing carry recurring intervals of exactly this kind: Hazard Communication at number 2, Control of Hazardous Energy at number 3 and Respiratory Protection at number 6. The citation does not come from a calendar date being missed. It comes from an interval quietly resetting to never.
This is also where a one-person environmental program shows its structural limit. The intervals with no filing attached are the first thing to drop when a safety manager picks up environmental on top of the job he was hired for, which is the mechanism described in what happens when EHS scope creep lands on a small manufacturer and in the 60 percent of the work your safety manager should not be doing.
What Changed This Year
This is the maintained section. Every year-specific item lives here so the three tables above can stay stable. Each entry below was verified against its primary source on October 14, 2026.
The GHGRP reporting year 2025 deadline moved again, to March 10, 2027. EPA published an interim final rule on October 14, 2026 (91 FR 65112, FR Doc 2026-20982) amending 40 CFR 98.3(b)(6) to set the reporting year 2025 deadline at March 10, 2027, effective on publication. Comments on the interim final rule are due November 30, 2026. EPA’s stated reasons include needing more time to act on its September 2025 GHGRP Reconsideration Proposal and the fact that e-GGRT would not have been ready for the prior date. This is the third date this one reporting year has carried: it started at March 31, 2026, moved once by a February 27, 2026 rule, and now sits at March 10, 2027. Any facility tracker or vendor calendar still showing the old autumn date is wrong, and so is any iSi page that has not been corrected.
There was no 2026 federal civil penalty inflation adjustment. OMB Memorandum M-26-11, dated April 17, 2026, cancelled it. The memorandum explains that the government shutdown prevented BLS from producing the October 2025 data, and because the statutory adjustment is keyed to October CPI-U with no alternative calculation, there is no 2026 multiplier and agencies continue at the 2025 levels. The Department of Labor confirmed the same outcome at 91 FR 31358 on May 27, 2026, stating it is making no adjustments under the Inflation Adjustment Act in 2026.
Did federal EPA and OSHA penalties go up in 2026?
No. OMB Memorandum M-26-11 of April 17, 2026 cancelled the 2026 inflation adjustment, because BLS did not publish the October 2025 CPI-U during the funding lapse. Agencies continue at 2025 levels, and the current column of 40 CFR 19.4 Table 1 still applies to penalties assessed on or after January 8, 2025.
The amounts are unchanged, and nothing in either document narrows citation authority. The operative figures, all in effect for 2026 and unchanged from 2025:
| Authority | Maximum | Status |
|---|---|---|
| OSHA serious, other-than-serious or posting violation, and per day for failure to abate | $16,550 | In effect for 2026, unchanged from 2025 (OSHA penalties) |
| OSHA willful or repeated violation | $165,514 | In effect for 2026, unchanged from 2025 (OSHA penalties) |
| EPCRA section 325(c)(1), which reaches Tier II and TRI violations | $71,545 per violation per day | In effect for 2026, unchanged from 2025 (40 CFR 19.4 Table 1) |
| EPCRA section 325(c)(2) | $28,619 per violation per day | In effect for 2026, unchanged from 2025 (40 CFR 19.4 Table 1) |
| Clean Air Act section 113(b) | $124,426 | In effect for 2026, unchanged from 2025 (40 CFR 19.4 Table 1) |
| Clean Water Act section 309(g)(2)(B) administrative | $27,378 per violation, $342,218 total | In effect for 2026, unchanged from 2025 (40 CFR 19.4 Table 1) |
The per-day structure on the EPCRA side is what turns a three-week slip on a Tier II filing into an exposure calculation rather than a paperwork problem. One caution when checking the figures yourself: OSHA’s penalties page carries an internal inconsistency, with introductory text referring to amounts assessed after January 15, 2026 while the table itself is labeled with an earlier adjustment year. Cite the amounts, not that page’s effective-date framing.
Tier II hazard categories are being replaced, and the timing is the part people get backwards. EPA’s conformity rule published June 22, 2026 (91 FR 37022), effective August 21, 2026, replaces the previous EPCRA hazard categories with the 118 OSHA hazard classes and categories from the 2024 Hazard Communication Standard, moves the definitions from 40 CFR 370.66 to 370.3, and conforms 370.30, 370.41 and 370.42. The compliance date for using the new hazard categories is January 1, 2028, and EPA expects the change to be reflected in reporting year 2027 section 312 reports due March 1, 2028. Read that carefully before rebuilding an SDS crosswalk: the March 1, 2027 Tier II filing still uses the old hazard categories. The new classes first apply to the filing after that one.
Title V got narrower effective October 26, 2026. Covered above under permit-driven dates. The certification frequency did not move; the set of applicable requirements being certified against did (91 FR 61026).
The 2021 industrial stormwater MSGP expired February 28, 2026 and is running on administrative continuance. Covered above. Existing coverage and the Part 4 monitoring schedule continue.
TSCA section 8(a)(7) PFAS reporting is still not open and no filing is currently due. EPA’s April 13, 2026 final rule (FR Doc 2026-07062) modified the start of the submission period, and EPA’s own section 8(a)(7) page, last updated April 16, 2026, does not state calendar start and end dates. It says the period begins a set interval after the effective date of a forthcoming rule revision. A November 2025 proposed rule would narrow scope through exemptions, with comments closed December 29, 2025. Treat the opening as pending, describe the trigger rather than a date, and re-verify the controlling Federal Register document before putting anything on a tracker.
Two rollbacks are proposed and neither is final. EPA proposed the Paper Manifest Sunset Rule on March 5, 2026 (91 FR 10862), which would phase out paper manifests and add e-Manifest registration requirements for RCRA transporters and certain PCB waste generators and transporters, with comments closed April 6, 2026. EPA proposed RMP amendments on February 24, 2026 (91 FR 8970) to roll back parts of the 2024 Safer Communities by Chemical Accident Prevention rule, with comments closed April 10, 2026. Nothing on a facility’s current calendar changes because of either one.
What did not change. Tier II March 1, TRI July 1, the February 1 through April 30 posting window, the March 2 electronic submission, the March 1 even-year Biennial Report, the five-year SPCC review and the three-year DOT hazmat interval all read the same in eCFR today as they did a year ago.
Three corrections worth carrying forward
Older compliance calendars, including earlier iSi ones, circulated three items that do not exist. First, there is no annual PCB report submitted to EPA in mid-July. 40 CFR 761.180(a) requires an annual document log prepared by July 1 and maintained at the facility. Second, there is no annual September Form U obligation; TSCA Chemical Data Reporting does not run on an annual cycle, so a facility that put it on every year’s list has been tracking a filing that is not due. Third, older lists carried an annual mercury inventory report under TSCA. Mercury reporting under 40 CFR 713 is triennial, so there is no annual item to place on the calendar.
What the Enforcement Numbers Actually Say
The two agencies moved in opposite directions last fiscal year, and a facility that reads only one of them will mis-size its exposure.
OSHA inspection volume fell. OSHA’s Current Enforcement Summary reports 30,273 total inspections in FY2025, down from 34,625 in FY2024, a decrease of about 12.6 percent. Programmed inspections, the planned visits that find a missing 300A posting, fell from 17,170 to 13,962. A plant manager reading only the penalty tables would conclude exposure went up; the inspection count says the probability of a planned visit went down.
EPA went the other way. EPA reports 2,127 civil enforcement cases concluded in FY2025, which it describes as the highest in nine years, with over $652 million in civil penalties assessed and more than $6.4 billion in compliance commitments. Criminal enforcement opened 187 new cases and charged 156 defendants. So the honest read is not that enforcement is receding. OSHA’s planned-inspection volume fell while EPA’s case volume hit a nine-year high, and the EPA-side obligations are the ones that carry per-day penalties.
There is a genuine counter-signal on the reporting side, and it is worth stating plainly because it cuts against the usual framing. EPA’s Greenhouse Gas Reporting Program page states that on September 12, 2025 EPA released a proposal to permanently remove program obligations for 46 source categories. The October 14, 2026 interim final rule moving reporting year 2025 to March 10, 2027 cites the need for time to act on that proposal, including the possibility of rescission. A deadline that has moved twice in nine months while the agency decides whether the program survives is a real case of a shrinking obligation. It is also the only one on this page.
Recordkeeping under Part 1904 does not appear in OSHA’s top-10 cited standards, and that is worth saying rather than implying otherwise. The 300A posting is not a top-10 citation. It is a first-fifteen-minutes finding.
The State Layer, Which Varies By State
Everything in this section VARIES BY STATE. None of it is a federal deadline and none of it should be treated as one.
March 1 for Tier II comes from 40 CFR 370.45(a) and does not vary. The portal, the form version, the fee and the number of recipients all do. EPA’s state-by-state Tier II page says each state sets its own requirements for submitting forms. Verified agencies and mechanics as of October 14, 2026:
| State | Agency (VARIES BY STATE) | Tier II submission mechanics (VARIES BY STATE) |
|---|---|---|
| Kansas | Kansas Department of Health and Environment, Right-to-Know Program | Web-based reporting system at tier2online.kdhe.ks.gov |
| Missouri | Missouri Emergency Response Commission | Missouri Tier Two electronic filing tool at apps1.mo.gov/merc |
| Oklahoma | Oklahoma Department of Environmental Quality | Tier2 Submit, sent through a specialized internet collection utility |
| Nebraska | Nebraska Department of Environment and Energy | Nebraska DEE Tier II System at deq-iis.ne.gov/tier2/ |
| Texas | Texas Commission on Environmental Quality, Tier II Chemical Reporting Program | STEERS Tier II online application |
| Colorado | Colorado Department of Public Health and Environment | Tier2 Submit file uploaded to the AccessGov platform. Emailed reports are not accepted |
Colorado is the example worth internalizing, and it is state-specific. Colorado requires the current Tier2 Submit version each year, and a report filed in an outdated version is invalidated. Colorado also uses single-point submission, so facilities do not separately send reports to LEPCs or fire departments unless those bodies impose their own requirement. A company that files in Colorado and in Kansas is running two different processes against one federal date, which is why portal verification belongs in January rather than in the last week of February.
State hazardous waste reporting is a separate obligation from the federal Biennial Report, and it also VARIES BY STATE. In Texas, the Texas Commission on Environmental Quality’s Industrial and Hazardous Waste Annual Waste Summary is due annually for the prior calendar year: March 1 if filed electronically through STEERS, and January 25 if filed on paper Form 00436. Registered generators and reverse distributors with active solid waste registrations must file, and large quantity generators producing more than 2,200 pounds in any calendar month must file electronically. That is an annual Texas report, not the federal biennial one, and a Texas facility owes both in the same even-numbered years. In Missouri, small and large quantity generators file the Generator’s Hazardous Waste Summary Report, Part 1, on paper or through MoGEM E-Reporting; the Missouri Department of Natural Resources publication does not state a report due date, and it does state that fee invoices are issued each November with payment due on or before January 1. Confirm the Missouri report date with the Waste Management Program rather than inferring one.
One simplification is worth stating explicitly, because readers in these markets often assume a variation that does not exist. Kansas, Missouri, Oklahoma, Nebraska, Texas and Colorado are all federal OSHA jurisdiction for private-sector employers. None of the six has an OSHA-approved State Plan covering private employers, so the posting window, the March 2 electronic submission and every Part 1910 interval in the tables above apply uniformly across all six with no state-plan variation.
Air and water permitting are where the real divergence sits. Title V permits are issued and administered by the state air agency, and the annual compliance certification and semiannual monitoring report dates come from that permit. In states with delegated NPDES authority the EPA MSGP does not apply and the state industrial stormwater general permit does. For both, read the permit rather than a calendar.
How to Run This at One Facility
The sequence that holds up over a few years is short.
Tag every obligation with its clock. Statutory dates get zero-flexibility treatment. Rule-based dates get a quarterly Federal Register check against the controlling document, not against a summary. Permit-driven dates get pulled from the permit portfolio, permit by permit, when the permit is issued or renewed. Anniversary intervals go on a per-employee and per-plan tracker with the last-completed date on each line, because that date is the deadline.
Verify state portals in January, not in late February. The federal date does not move and the portal sometimes does.
Then assign an owner per filing rather than per agency. Environmental has EPA is the sentence that lets the PHMSA renewal and the electronic injury submission fall between two chairs, because neither one looks like the agency anyone was assigned.
Running that across EPA, OSHA, DOT and a stack of permit-specific dates is standing work. It does not scale down to whoever is least busy in February, and it does not fit in the margins of a safety manager’s week. iSi handles the recurring filings, the anniversary trackers and the quarterly Federal Register verification as facility support for facilities that keep the judgment calls in house, or as a full EHS COOP retainer for facilities that want the whole program layer staffed from outside. That model came out of two decades of embedded aerospace experience, where a major aerospace OEM needed the surrounding compliance work run continuously rather than audited once a year. If you want a facility-specific version of the four calendars above, mapped to your permits and NAICS codes, send us the permit list and you will get a same-day response.
Sources
All URLs fetched and verified 2026-10-14.
- eCFR, 29 CFR 1904.32, annual summary preparation, certification and the February 1 through April 30 posting: https://www.ecfr.gov/current/title-29/part-1904/section-1904.32 (verified 2026-10-14)
- eCFR, 29 CFR 1904.41, electronic submission tiers and the March 2 date: https://www.ecfr.gov/current/title-29/subtitle-B/chapter-XVII/part-1904/subpart-E/section-1904.41 (verified 2026-10-14)
- eCFR, 40 CFR Part 370, Tier II March 1 date at 370.45(a) and thresholds at 370.10: https://www.ecfr.gov/current/title-40/chapter-I/subchapter-J/part-370 (verified 2026-10-14)
- EPA, Hazardous Chemical Inventory Reporting (Tier II): https://www.epa.gov/epcra/hazardous-chemical-inventory-reporting (verified 2026-10-14)
- EPA, State Tier II Reporting Requirements and Procedures: https://www.epa.gov/epcra/state-tier-ii-reporting-requirements-and-procedures (verified 2026-10-14)
- eCFR, 40 CFR 372.30(d), TRI July 1 deadline: https://www.ecfr.gov/current/title-40/chapter-I/subchapter-J/part-372/subpart-B/section-372.30 (verified 2026-10-14)
- eCFR, 40 CFR 372.25, TRI activity thresholds: https://www.ecfr.gov/current/title-40/part-372/subpart-B/section-372.25 (verified 2026-10-14)
- eCFR, 40 CFR 372.45, EPCRA 313 supplier notification: https://www.ecfr.gov/current/title-40/part-372/subpart-C/section-372.45 (verified 2026-10-14)
- eCFR, 40 CFR 262.41, RCRA Biennial Report and Form 8700-13 A/B: https://www.ecfr.gov/current/title-40/part-262/subpart-D/section-262.41 (verified 2026-10-14)
- eCFR, 40 CFR 262.18(d), LQG and SQG re-notification: https://www.ecfr.gov/current/title-40/part-262/section-262.18 (verified 2026-10-14)
- eCFR, 40 CFR 262.17(a)(7), LQG initial training and annual review: https://www.ecfr.gov/current/title-40/part-262/section-262.17 (verified 2026-10-14)
- eCFR, 40 CFR 260.10, generator kilogram thresholds: https://www.ecfr.gov/current/title-40/part-260/section-260.10 (verified 2026-10-14)
- eCFR, 40 CFR 70.6, Title V semiannual monitoring reports and the not-less-than-annual compliance certification: https://www.ecfr.gov/current/title-40/part-70/section-70.6 (verified 2026-10-14)
- eCFR, 40 CFR 70.2, major source definition: https://www.ecfr.gov/current/title-40/part-70/section-70.2 (verified 2026-10-14)
- eCFR, 40 CFR 112.5, five-year SPCC plan review, six-month amendment and PE certification: https://www.ecfr.gov/current/title-40/chapter-I/subchapter-D/part-112/subpart-A/section-112.5 (verified 2026-10-14)
- eCFR, 40 CFR 112.1(d)(2), SPCC applicability thresholds: https://www.ecfr.gov/current/title-40/part-112/section-112.1 (verified 2026-10-14)
- eCFR, 40 CFR 122.41(l)(4), NPDES monitoring reports and DMRs: https://www.ecfr.gov/current/title-40/chapter-I/subchapter-D/part-122/subpart-C/section-122.41 (verified 2026-10-14)
- eCFR, 40 CFR 68.190(b), five-year RMP update and resubmission: https://www.ecfr.gov/current/title-40/part-68/section-68.190 (verified 2026-10-14)
- eCFR, 40 CFR 761.180(a), PCB annual document log prepared by July 1 and maintained on site: https://www.ecfr.gov/current/title-40/part-761/section-761.180 (verified 2026-10-14)
- eCFR, 49 CFR 172.704, DOT hazmat training intervals and records: https://www.ecfr.gov/current/title-49/part-172/subpart-H/section-172.704 (verified 2026-10-14)
- eCFR, 40 CFR 19.4 Table 1, current penalty column applying to penalties assessed on or after January 8, 2025: https://www.ecfr.gov/current/title-40/chapter-I/subchapter-A/part-19/section-19.4 (verified 2026-10-14)
- OSHA, 29 CFR 1910.134, annual fit testing and retraining: https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.134 (verified 2026-10-14)
- eCFR, 29 CFR 1910.95, annual audiogram and annual training: https://www.ecfr.gov/current/title-29/part-1910/subpart-G/section-1910.95 (verified 2026-10-14)
- OSHA, 29 CFR 1910.147, annual periodic inspection and certification: https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.147 (verified 2026-10-14)
- OSHA, 29 CFR 1910.1030, annual Exposure Control Plan review and annual training: https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1030 (verified 2026-10-14)
- OSHA, 29 CFR 1910.157, extinguisher inspection, maintenance check and training: https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.157 (verified 2026-10-14)
- OSHA, 29 CFR 1910.146(d)(14), permit space program review within one year after each entry: https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.146 (verified 2026-10-14)
- OSHA, 29 CFR 1910.178(l)(4)(iii), powered industrial truck operator evaluation: https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.178 (verified 2026-10-14)
- eCFR, 29 CFR 1910.119, PSM intervals: https://www.ecfr.gov/current/title-29/part-1910/subpart-H/section-1910.119 (verified 2026-10-14)
- eCFR, 29 CFR 1910.120(e)(8), annual eight-hour HAZWOPER refresher: https://www.ecfr.gov/current/title-29/part-1910/subpart-H/section-1910.120 (verified 2026-10-14)
- Federal Register, 91 FR 65112 (FR Doc 2026-20982), GHGRP reporting year 2025 deadline moved to March 10, 2027, effective 2026-10-14: https://www.federalregister.gov/documents/2026/10/14/2026-20982/extending-the-reporting-deadline-under-the-greenhouse-gas-reporting-rule-for-reporting-year-2025-to (verified 2026-10-14)
- Federal Register, 91 FR 37022 (FR Doc 2026-12426), EPCRA hazard category conformity with the 2024 OSHA Hazard Communication Standard, effective 2026-08-21, compliance date 2028-01-01: https://www.federalregister.gov/documents/2026/06/22/2026-12426/epcra-hazardous-chemical-inventory-reporting-requirements-conformity-with-the-2024-osha-hazard (verified 2026-10-14)
- Federal Register, 91 FR 61026 (FR Doc 2026-19671), scope of applicable requirements under state and federal operating permit programs, effective 2026-10-26: https://www.federalregister.gov/documents/2026/09/25/2026-19671/clarifying-the-scope-of-applicable-requirements-under-state-operating-permit-programs-and-the (verified 2026-10-14)
- Federal Register, 91 FR 8970 (FR Doc 2026-03633), proposed RMP amendments: https://www.federalregister.gov/documents/2026/02/24/2026-03633/accidental-release-prevention-requirements-risk-management-programs-under-the-clean-air-act-common (verified 2026-10-14)
- Federal Register, 91 FR 10862 (FR Doc 2026-04366), proposed Paper Manifest Sunset Rule: https://www.federalregister.gov/documents/2026/03/05/2026-04366/paper-manifest-sunset-rule-modification-of-the-hazardous-waste-manifest-regulations (verified 2026-10-14)
- OMB Memorandum M-26-11, Cancellation of Penalty Inflation Adjustments for 2026, dated 2026-04-17: https://www.whitehouse.gov/wp-content/uploads/2026/04/M-26-11-Cancellation-of-Penalty-Inflation-Adjustments-for-2026-Regarding-the-Federal-Civil-Penalties-Inflation-Adjustment-Act-Improvements-Act-of-2015.pdf (verified 2026-10-14)
- Federal Register, 91 FR 31358 (FR Doc 2026-10456), Department of Labor penalty adjustments for 2026, no adjustment made: https://www.federalregister.gov/documents/2026/05/27/2026-10456/department-of-labor-federal-civil-penalties-inflation-adjustment-act-annual-adjustments-for-2026 (verified 2026-10-14)
- OSHA, current penalty amounts: https://www.osha.gov/penalties (verified 2026-10-14)
- OSHA, Injury Tracking Application FAQs: https://www.osha.gov/injuryreporting/faqs (verified 2026-10-14)
- OSHA, Current Enforcement Summary, FY2025 inspection totals: https://www.osha.gov/enforcement/current-enforcement-summary (verified 2026-10-14)
- OSHA, Top 10 Most Frequently Cited Standards, FY2026 preliminary: https://www.osha.gov/top10citedstandards (verified 2026-10-14)
- OSHA, State Plans: https://www.osha.gov/stateplans (verified 2026-10-14)
- OSHA, Recordkeeping Forms and five-year retention under 29 CFR 1904.33: https://www.osha.gov/recordkeeping/forms (verified 2026-10-14)
- EPA, 2021 MSGP Appendix O, Summary of Reports and Permit Submittals: https://epa.gov/sites/default/files/2021-01/documents/2021_msgp_-_appendix_o_-_summary_of_reports_permit_submittals.pdf (verified 2026-10-14)
- EPA, Stormwater Discharges from Industrial Activities, 2021 MSGP and administrative continuance: https://www.epa.gov/npdes/stormwater-discharges-industrial-activities-epas-2021-msgp (verified 2026-10-14)
- EPA, Stormwater Discharges from Industrial Activities, Proposed 2026 MSGP: https://www.epa.gov/npdes/stormwater-discharges-industrial-activities-epas-proposed-2026-msgp (verified 2026-10-14)
- EPA, Greenhouse Gas Reporting Program: https://www.epa.gov/ghgreporting (verified 2026-10-14)
- EPA, TSCA Section 8(a)(7) Reporting and Recordkeeping: https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/tsca-section-8a7-reporting-and-recordkeeping (verified 2026-10-14)
- EPA, Enforcement and Compliance Assurance Results for FY 2025: https://www.epa.gov/enforcement/enforcement-and-compliance-assurance-results-fy-2025-year-powering-great-american (verified 2026-10-14)
- PHMSA, Hazmat Registration Information, July 1 through June 30 registration year: https://www.phmsa.dot.gov/registration/registration-information (verified 2026-10-14)
- TCEQ, Industrial and Hazardous Waste Reporting (VARIES BY STATE): https://www.tceq.texas.gov/permitting/registration/ihw/waste_reporting.html (verified 2026-10-14)
- Missouri DNR, Generator’s Hazardous Waste Summary Report (VARIES BY STATE): https://dnr.mo.gov/print/document-search/pub2254 (verified 2026-10-14)