Chemical Reporting Changes

Changes in the law might affect your facility and hazardous materials reporting

This Hazardous Materials Reporting Chart explains changes to the inventory reporting requirements in the Health & Safety Code (HSC), Chapter 6.95, Article 1, §25507. These changes are the result of the following legislative bills:

  • Assembly Bill 408  Effective January 1, 2012
  • Senate Bill  483    Effective January 1, 2014
  • Senate Bill 1261   Effective January 1, 2015

The San Diego County Code (SDCC) contains additional exemptions or higher reporting thresholds for specified hazardous materials.

Please review the Hazardous Materials Reporting Chart to determine if your facility is affected by the changes to the reporting requirements. When applicable, a facility must update the hazardous materials inventory using the California Environmental Reporting System (CERS and submit the changes for review and acceptance by the inspector.  Please be advised that facility permit fees are based on the inventory reported in CERS; therefore, if a facility does not routinely review and submit their inventory changes in CERS based on the law it may result in incorrect fees on your annual facility permit invoice.   

State law requires changes or updates to a facility’s reportable inventory be submitted in CERS within 30 days (Cal.HSC §25508.1).       

The type of hazardous material in the chart and its use is pursuant to law.  If the material and use specified are not relevant for the facility, the reporting thresholds in State law are >55 gallons (liquids), >500 pounds (solids), >200 cubic feet (gases), or at the threshold planning quantity for extremely hazardous substances.  

If you have any questions please contact your area Inspector or the Hazardous Materials Duty Desk Specialist at 858-505-6880 or


 Hazardous Materials Reporting Chart



Facility Reports Electronically in CERS

Carbon Dioxide (CO2) for Beverage Carbonation

Report if > 6000 cubic feet for non-cryogenic compressed gas OR >3500 cubic feet for cryogenic compressed gas.   [SDCC]

Carbon Dioxide (CO2)

Report if facility handles at any one time during the reporting year cryogenic, refrigerated, or compressed gas in quantities >1,000 cubic feet at standard temperature and pressure.  [HSC 25507]

Compressed Air used in Emergency Response

No requirement to report in CERS compressed air in cylinders, bottles, and tanks used by fire departments and other emergency response organizations (public agency) for the purpose of emergency response and safety.  [HSC 25507]

Consumer Products-Retail Establishment*

No requirement to report in CERS if all specified conditions are met. [HSC 25507]  

Closed Fire Suppression System Exemption

No requirement to report in CERS. [SDCC]

Fluid in hydraulic system

Report if the combined storage capacity of oils (including used oil) at the facility is ≥1,320 gallons. [HSC 25507]

Gases – Refrigerants

No requirement to report in CERS closed cooling systems containing fluorocarbons, chlorocarbons and chlorofluorocarbons used for air conditioning and refrigeration.  

No requirement to report in CERS refrigerant gases, other than ammonia or flammable gas in a closed cooling system that are used for comfort or space cooling for computer rooms. 

[HSC 25507]

Inert Gas – Simple Asphyxiation or Release of Pressure

This applies for a hazardous material that is a compressed gas, at standard temperature and pressure, and for which the only health and physical hazards are simple asphyxiation and the release of pressure.  Cal/EPA has developed guidance to determine if a material qualifies for this reporting threshold:

Report if facility handles at any one time during the reporting year cryogenic, refrigerated, or compressed gas in quantities ≥1,000 cubic feet at standard temperature and pressure. [HSC 25507]

Irritant or Sensitizer only

This applies for a solid or liquid hazardous material that is classified as a hazard solely as an irritant or sensitizer. Cal/EPA developed guidance to determine if a material qualifies for this reporting threshold:

The reporting quantity is >5,000 pounds for solids or >550 gallons for liquids. [HSC 25507]


Lubricating Oil

Report lubricating oil if volume of each type exceeds 55 gallons OR the total volume of all types exceeds 275 gallons.  [HSC 25507]

NOTE:  Does not apply to used oil which is reportable at >55 gallons. 

Specified Medical Gases

Report at >200 cubic feet unless the conditions below apply:

Report if facility handles at any one time during the reporting year cryogenic, refrigerated, or compressed gas in quantities of >1000 cubic feet for oxygen, nitrogen, and nitrous oxide maintained by a physician, dentist, podiatrist, veterinarian, pharmacist, or emergency medical service provider. [HSC 25507]

Oil-Filled Electrical Equipment (not contiguous to an electric facility)

Report if the aggregate storage capacity of oil (including used oil) at the facility is ≥1,320 gallons. [HSC 25507]

Authorized Paint Care Facility

Report paint >55 gallons or  >500 pounds unless the conditions below apply:

Report the paint when the authorized Paint Care business handles at any one time during the reporting year a total weight of 10,000 pounds of solid hazardous materials or a total volume of 1,000 gallons of liquid hazardous materials.  [HSC 25507]


Report if equal to or more than 23.25 lbs or 5.5 gallons or 200 ft³ unless used on premises for heating, cooling or cooking.  (1 gallon = 4.24 lbs)

Report on premises use, storage, or both if more than 1,000 gallons that is for the sole purpose of cooking, cooling/heating the employee work areas, and heating water.   [SDCC]

Unstaffed Remote Facilities

(conditional reporting requirements do apply)**

Located in an isolated sparsely populated area if the types & quantities are limited to one or more of the following:  [Situated at least one-half mile from the nearest occupied structure to be remote].  [HSC 25507.2]

  • 1000 cubic feet of compressed gases (asphyxiation and pressure hazard only)
  • 500 gallons of combustible liquids used as a fuel
  • Corrosive liquids not to exceed 500 pounds of extremely hazardous substances, used as electrolytes, and in closed containers
  • 500 gallons lubricating and hydraulic fluids 
  • 1,200 gallons of flammable (hydrocarbon) gas used as fuel
  • Report quantity of mineral oil contained within electrical equipment, such as transformers, bushings, electrical switches, and voltage regulators, if the spill prevention control and countermeasure (SPCC) plan has been prepared for quantities that meet or exceed 1,320 gallons


[HSC 25507(a)(3)(A)&(B)], 
SDCC = San Diego County Code

HSC = California Health and Safety Code


Reporting chemical inventory in CERS guidance:

  • Compressed Gas: For a compressed gas, when the gas is determined to meet or exceed threshold quantities at standard temperature and pressure, it shall be reported in the physical state at which it is stored.  (For example, liquefied nitrogen = report in gallons)  HSC 25507(a)(1)(B)
  • If the material is an extremely hazardous substance (EHS) as defined in Section 355.61 of Title 40 of the Code of Federal Regulations, all amounts shall be reported in pounds in CERS. [HSC 25507(a)(1)(B)].   The U.S. EPA’s Consolidated List of Lists will identify the EHS chemicals that are below 500 pounds that must be reported in CERS [HSC 25507(a)(3)(A)&(B)], reference EPCRA Section 302:

Consumer Products guidance: 

  • Retail establishment means a business that sells consumer products prepackaged for distribution to, and intended for use by, the general public. A retail establishment may include storage areas or storerooms in establishments that are separated from shelves for display areas but maintained within the physical confines of the retail establishments. A retail establishment does not include a pest control dealer, as defined in Section 11407 of the Food and Agricultural Code.  HSC 25501(q)
  • Hazardous material contained solely in a consumer product, handled at, and found in, a retail establishment and intended for sale to, and for the use by, the public. The exemption provided for in this paragraph shall NOT apply to a consumer product handled at the facility which manufactures that product, or a separate warehouse or distribution center of that facility, or where a product is dispensed on the retail premises. HSC 25507
  • Consumer product means a commodity used for personal, family, or household purposes, or is present in the same form, concentration, and quantity as a product prepackaged for distribution to and use by the general public.  HSC 25501(j)  

**   Unstaffed Remote Facilities Reporting Requirements:   HSC 25507.2

  • Situated at least one-half mile from the nearest occupied structure. 
  • A one-time business plan submittal, except for the emergency response plan and training elements specified in paragraphs (3) and (4) of subdivision (a) of Section 25505, is submitted in CERS by the owner/operator. 
  • Submit facility changes within 30 days in CERS. 
  • The one-time business plan submittal is subject to a verification inspection by the unified program agency.
  • The facility is secured and not accessible to the public.
  • Warning signs are posted and maintained for hazardous materials pursuant to the California Uniform Fire Code.