Tier II Reporting

How Tier II Reporting Works in Alabama

If your facility stores hazardous chemicals above the federal thresholds, the Alabama Emergency Response Commission wants to know every year by March 1st -- and the state has a few wrinkles on top of the federal rules that trip people up more than you'd expect.

Last reviewed: July 2026

The Alabama Emergency Response Commission -- AERC, though you'll still see the older name SERC in some paperwork -- is co-chaired by the Alabama Department of Environmental Management and the Alabama Emergency Management Agency. ADEM is the one that actually receives your Tier II data day to day.

Alabama stopped accepting anything but electronic filing back in November 2017, when the AERC voted to require digital submission for every regulated facility.

Who has to file, and when

Same federal baseline as everywhere else: a hazardous chemical requiring an SDS at 10,000 pounds or more, or an extremely hazardous substance at its threshold planning quantity or 500 pounds, whichever is lower.40 CFR 370.10 If you're already tracking this for the federal filing, you're tracking what Alabama needs -- the thresholds don't change at the state line.

The deadline is March 1st for the previous calendar year. What's easy to miss is that Tier II isn't the only clock running -- a new extremely hazardous substance on site triggers a separate, one-time Section 302/303 notification to AERC and your LEPC, and new facilities get three months from becoming subject to OSHA's hazard communication rules to get their SDS list in under Section 311. Neither of those follows the March 1st calendar.

Where your report actually goes

Alabama gives you exactly two electronic paths. You can file through E-Plan, or you can use EPA's Tier2 Submit software and email the exported .t2s file directly to ADEM at al312@adem.alabama.gov. There's no paper option anymore and no third path.

The two paths aren't equivalent in cost. E-Plan charges $25 per facility per year, and it won't finalize your submission until that fee clears. Tier2 Submit, by contrast, is free -- you download the software, build your report, export it as .t2s, and email it with the facility name, filing year, and Master ID number in the subject line. That's genuinely the entire state-specific instruction for the free path.

Filing with AERC doesn't automatically take care of your LEPC or your local fire department. Different counties want different formats -- some are fine with an emailed PDF, some still want paper -- so ADEM's own guidance is blunt about it: contact your county EMA and fire department directly rather than assuming your AERC submission covers them too.

The Master ID is where most of the confusion lives

Every Alabama filing needs a Master ID number, and this is genuinely the part people get stuck on. It's ADEM's internal tracking number for your facility, and it's separate from your E-Plan Access ID -- two different numbers, both required if you file through E-Plan, and mixing them up is common enough that ADEM built an FAQ entry just for it.

If your facility has ever held any ADEM permit for anything -- air, water, waste, doesn't matter which program -- you already have a Master ID. Look it up yourself through ADEM's eFile tool by searching your permit number. If you've never held one, you'll need to contact ADEM's EPCRA coordinator to get a number assigned before you can file.

I filed with Alabama a few years ago, so I'll just make a new E-Plan account to be safe.
Don't. If you've filed any time since 2016, you already have an E-Plan account, and ADEM specifically warns against creating a duplicate -- it's exactly the kind of mismatch that holds up a filing in the one season you don't want anything held up.

What actually goes wrong every filing season

A genuinely useful, low-stakes fact from Alabama's own FAQ: you cannot get in trouble for over-reporting. More information helps first responders, and there's no penalty for flagging a borderline chemical you weren't sure about. A fair number of facilities under-report out of a vague worry that including too much invites scrutiny -- ADEM's guidance says the opposite is true.

Two smaller but recurring trip-ups: don't import a .t2s file older than the 2018 format into a current-year Tier2 Submit install, since the software isn't guaranteed to handle it cleanly. And keep your confirmation after you submit -- E-Plan gives you a payment confirmation page, the email path gets you a receipt from ADEM -- because federal rules require proof of receipt on-site from all three entities, and "I'm pretty sure I sent it" doesn't hold up if anyone ever asks.

Where HazRecord fits

HazRecord handles the part that eats the most time before you ever touch E-Plan or Tier2 Submit -- keeping your chemical inventory, SDS records, and threshold tracking current all year instead of rebuilding it from scratch in a February scramble. When it's time to file, it generates a validated .t2s file for the free ADEM email path, with your Master ID and the correct subject-line format already built into the export.

This guide is for general informational purposes only. It is not legal advice. Facilities remain responsible for verifying and submitting required reports to the appropriate federal, state, tribal, and local agencies.

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