40 CFR Part 370 Every filing checked against the federal rule — not assumed

The most rigorous EPCRA Tier II & TRI filing pack a multi-site company can use.

InventoryIQ assembles a documentation-complete filing pack — every required form, every threshold determination, every hazard classification, and every jurisdictional portal submission — checked against the letter of 40 CFR Part 370 and EPCRA §§311–313 before a certified specialist releases it.

Every subsection of 40 CFR Part 370Five statutory filing elements, gate-checkedSDS extraction · CAS validation · threshold aggregationSpecialist release on every pack5-business-day SLA
Why filings fail

A single missing chemical or misclassified hazard can trigger a $174,985/day penalty.

A multi-site company's EPCRA compliance is only as strong as the inventory behind it. Miss a reportable chemical, mis-map a hazard category under the new HazCom 2024 alignment, skip a state-specific threshold, or fail to file in every jurisdiction — and the company faces EPA enforcement, public notice, and per-day fines that compound fast.

Most EHS teams run this by hand, from memory, once a year. The rule has not been read end-to-end since the last time it mattered. That is exactly where completeness gaps hide.

InventoryIQ exists to close that gap with a single, exhaustive standard applied identically to every facility.

$174,985
per day, per violation — EPA maximum penalty for non-filing
The benchmark

Measured against the letter of the rule — subsection by subsection.

We do not summarize the law and hope. Every filing is scored against a versioned rule pack tied to the exact text of 40 CFR Part 370 and EPCRA §§311–313. These are the provisions each pack is held to.

40 CFR §370.30

Five required content elements

Facility identification, chemical inventory (CAS, hazard categories, max/average amounts), storage locations, and certification — all present, or the pack does not release.

40 CFR §370.41

Threshold determination

Every chemical is checked against the 10,000 lb standard hazardous threshold and 500 lb EHS threshold, plus any state-specific lower thresholds — computed deterministically, never estimated.

40 CFR §370.42

Hazard classification mapping

GHS hazard statements from SDSs are mapped to the five Tier II hazard categories (fire, sudden release, reactive, acute, chronic) and the new HazCom 2024 categories — verified by a certified reviewer.

40 CFR §370.40

Every required recipient

SERC, LEPC, and fire department for each facility — established by jurisdictional search, not assumption.

40 CFR §370.60

State-specific portal compliance

Each state's Tier II portal, fee schedule, and delivery method (e.g., Tier2 Submit, state system, paper) is identified and followed.

EPCRA §313

TRI Form R where applicable

For facilities in covered NAICS codes with chemicals above TRI thresholds, the Form R is prepared and filed by July 1 — sequenced on the calendar so nothing is missed.

How a filing is built

Intake to specialist release, with deterministic gates the AI cannot overrule.

AI extracts and drafts. Deterministic rules — running as code, outside the model — decide what is complete. A certified EHS professional (CHMM) signs every release. That order is never reversed.

01

Compliance Gap Scan

Upload your SDS binder and facility list. We return a free completeness read: which chemicals are reportable, which thresholds are triggered, and which jurisdictions need filings.

02

SDS extraction & validation

As your authorized clerical agent, we ingest SDSs, extract CAS numbers, hazard statements, and physical states, and validate against authoritative sources (PubChem, CAMEO).

03

Threshold & hazard aggregation

Max and average on-site quantities are aggregated per chemical per facility. Hazard categories are mapped under both current and HazCom 2024 rules — no legal opinions, no invented facts.

04

Deterministic completeness gates

Thresholds reconcile to the SDS to the pound; hazard mappings are checked against the rule; recipient list is resolved; SCRA is screened. Any failure blocks release.

05

Specialist release

A certified EHS professional (CHMM) reviews the threshold and classification calls and signs the release. High-volume or complex facilities route to attorney review first.

06

Delivery

You receive the pack: completed Tier II forms (and TRI Form R if applicable), evidence log, jurisdictional submission receipts, and a 12-month compliance calendar — ready for your authorized official to certify and submit.

The bar we hold

Rigor you can measure.

100%
Specialist-released
No pack ships without a CHMM signature.
5 days
Standard SLA
From complete intake to released pack.
<1%
Critical-defect target
Tracked against a gold-standard filing library.
3
Validation sources
PubChem · CAMEO · EPA's EHS/TPQ list, every applicable chemical.
Why InventoryIQ

Built to be the most thorough option a multi-site company has.

Documentation-complete, by design

The deliverable is completeness itself — every required form, threshold determination, and hazard classification accounted for or explicitly exception-coded. Nothing is left implicit.

Deterministic, not vibes

The gates that decide completeness are code, not a model's opinion. A drafting error cannot slip past a regulatory requirement.

In its lane, on purpose

We prepare documentation and run searches as your clerical agent. We never give legal advice, certify the filing, or interact with regulators on your behalf.

Engagement

Flat fee, per released filing. No contingency, ever.

Simple, predictable, and aligned with a documentation standard — not a cut of any penalty avoidance.

  • A free Compliance Gap Scan before you commit — see exactly what is missing.
  • One flat fee per released filing pack; disclosed pass-through search fees.
  • Optional fixed-fee attorney review for complex or multi-state filings.
  • Optional TRI Form R add-on for covered facilities.
FAQ

Questions, answered precisely.

Is InventoryIQ a law firm?
No. InventoryIQ, a service of Your Deputy, Obuke LLC, provides documentation-completeness services. It is not a law firm, does not provide legal advice, and does not represent you in any legal matter. Attorney review is available and recommended for complex or high-penalty-exposure filings.
Do you file the reports or interact with regulators?
No. InventoryIQ prepares the documentation and populates the forms. The client's authorized official certifies and submits each filing. We never communicate with SERCs, LEPCs, fire departments, or EPA on your behalf.
What makes a filing 'complete'?
Completeness is defined by the rule: all required content elements present, thresholds verified, hazard classifications mapped correctly, recipients identified, and jurisdictional portal requirements met. Deterministic gates enforce each one before release.
How fast is it?
The standard SLA is five business days from complete intake to a specialist-released pack. The free Gap Scan is returned much sooner and tells you exactly what is still needed.
How are you priced?
A flat fee per released filing pack, plus disclosed pass-through search costs. No contingency and no percentage of any penalty avoided.

See what's missing before it costs you a penalty.

Start with a free Compliance Gap Scan. Send your SDS binder and facility list and we'll return a completeness read against every subsection of 40 CFR Part 370.

Documentation-completeness service · not legal advice · your authorized official certifies every filing.