Skip to main content

Understanding Regulatory Chemical Lists

What Are Regulatory Chemical Lists?

Regulatory chemical lists are official catalogs maintained by government agencies (federal, state, and international) that identify chemicals requiring special handling, reporting, labeling, or monitoring in the workplace and environment. If your business manufactures, processes, stores, or uses chemicals, some of those chemicals may appear on one or more of these lists — and that means specific legal obligations apply to you.

Think of it like this: just as a restaurant needs to know which foods contain common allergens, any business handling chemicals needs to know which of its chemicals appear on government regulatory lists — and what that means for safety, labeling, reporting, and worker protection.


Why This Matters

Failing to comply with chemical regulations can result in:

  • OSHA fines of up to $16,131 per violation (or $161,323 for willful violations)
  • EPA fines of up to $62,689 per day per violation for TRI non-reporting
  • California Prop 65 lawsuits with penalties of up to $2,500 per day per violation
  • CERCLA liability for cleanup costs that can reach millions of dollars
  • Criminal penalties in severe cases of knowing endangerment

Beyond fines, non-compliance creates real safety risks for workers and communities. Regulatory lists exist because the chemicals on them have been scientifically determined to pose specific health or environmental hazards.


The Lists Tellus Tracks

Tellus monitors 15 regulatory lists across federal, state, and international jurisdictions. Here is what each list is, who maintains it, and what it means when your chemical appears on it.

Federal Lists

1. OSHA Permissible Exposure Limits (PEL)

AuthorityOccupational Safety and Health Administration (OSHA)
JurisdictionFederal (all U.S. workplaces)
Chemicals~470 substances
UpdatesRarely (most PELs date to 1971; changes require federal rulemaking)
Official Source29 CFR 1910.1000 Tables Z-1, Z-2, Z-3

What it is: The legal maximum airborne concentration of a chemical that workers may be exposed to over an 8-hour work shift. These are legally enforceable limits — if air monitoring shows levels above the PEL, your company is in violation of OSHA regulations.

What it means for your business:

  • You must keep workplace air concentrations below the PEL
  • Industrial hygiene monitoring may be required
  • Engineering controls (ventilation, enclosures) must be implemented before relying on respirators
  • Workers must be informed of exposure levels

Example: Benzene (CAS 71-43-2) has an OSHA PEL of 1 ppm (8-hour TWA). Any workplace using products containing benzene must ensure air levels stay below this limit.


AuthorityNational Institute for Occupational Safety and Health (NIOSH)
JurisdictionFederal (advisory, not legally enforceable)
Chemicals~700 substances
UpdatesOngoing (NIOSH updates recommendations as new science emerges)
Official SourceNIOSH Pocket Guide to Chemical Hazards

What it is: NIOSH's scientifically recommended maximum exposure level, typically more protective than OSHA PELs. While not legally binding, they represent the best available science on safe exposure levels.

What it means for your business:

  • Not legally required, but following RELs reduces liability and protects workers
  • Many companies voluntarily adopt RELs as their internal standards
  • If OSHA has no PEL for a chemical but NIOSH has a REL, that REL becomes an important guideline
  • Tellus lets you configure whether to use NIOSH RELs as your default standard (see Compliance Settings)

Example: Formaldehyde (CAS 50-00-0) has an OSHA PEL of 0.75 ppm but a NIOSH REL of 0.016 ppm — nearly 50 times more protective. A safety-conscious company might target the NIOSH level.


3. ACGIH Threshold Limit Values (TLV)

AuthorityAmerican Conference of Governmental Industrial Hygienists (ACGIH)
JurisdictionIndustry consensus (not a government agency)
Chemicals~700 substances
UpdatesAnnual (ACGIH updates TLVs each year based on latest research)
Official SourceACGIH TLV/BEI Documentation

What it is: Exposure guidelines developed by occupational health professionals based on the latest toxicological and epidemiological data. TLVs are often the most current exposure recommendations available.

What it means for your business:

  • Not legally binding, but widely respected as best practice
  • Many states adopt TLVs into their state OSHA plans, making them enforceable in those states
  • Insurance companies and courts may reference TLVs when evaluating workplace safety
  • ACGIH also classifies carcinogens (A1 = confirmed, A2 = suspected)

4. EPA Toxics Release Inventory (TRI / SARA 313)

AuthorityU.S. Environmental Protection Agency (EPA)
JurisdictionFederal
Chemicals~800 chemicals and chemical categories
UpdatesAnnual (effective January 1; chemicals added via federal rulemaking)
Official SourceEPA TRI Listed Chemicals

What it is: The Toxics Release Inventory, established under the Emergency Planning and Community Right-to-Know Act (EPCRA) Section 313, requires facilities to report annually how much of each listed toxic chemical they release into the environment or transfer off-site.

What it means for your business:

TRI reporting (Form R) is required if all three conditions are met:

  1. Your facility is in a covered industry (manufacturing, mining, utilities, and others with NAICS codes 21-33, 4911, 4931, 4939, 5112, 5171, 5172, 5174, 5179, 4246, 5622)
  2. You have 10 or more full-time equivalent employees
  3. You manufacture, process, or otherwise use a TRI-listed chemical above its threshold in a calendar year
ActivityStandard ThresholdPBT Chemical Threshold
Manufacturing or Processing25,000 lbs/year10–100 lbs/year (varies)
Otherwise Use10,000 lbs/year10–100 lbs/year (varies)

Key deadlines:

  • Form R (or Form A for small quantities): Due July 1 of the following year
  • Reports are submitted to EPA and your state environmental agency

Example: A paint manufacturer using 15,000 lbs/year of Toluene (CAS 108-88-3, threshold 25,000 lbs for manufacturing) would NOT need to report. But if they use 30,000 lbs, a Form R is required by July 1 of the next year.


5. CERCLA Hazardous Substances (Superfund)

AuthorityU.S. Environmental Protection Agency (EPA)
JurisdictionFederal
Chemicals~800 hazardous substances
UpdatesRarely (requires federal rulemaking)
Official Source40 CFR 302.4 — Table 302.4

What it is: The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA, commonly known as "Superfund") assigns a Reportable Quantity (RQ) to each listed hazardous substance. If you release an amount equal to or greater than the RQ within any 24-hour period, you must immediately notify the National Response Center.

What it means for your business:

  • Know the RQ for every CERCLA-listed chemical on your site
  • If a spill or release meets or exceeds the RQ, you must call the National Response Center at 1-800-424-8802 within 24 hours
  • RQ values range from 1 pound (highly toxic substances like mercury) to 5,000 pounds (less toxic substances like acetone)
  • Failure to report is a federal crime

Example: Your facility has a spill of 15 lbs of Benzene (CAS 71-43-2, RQ = 10 lbs). Since 15 lbs exceeds the 10 lb RQ, you must report this spill to the National Response Center immediately.


6. EPCRA Section 302 — Extremely Hazardous Substances (EHS)

AuthorityU.S. Environmental Protection Agency (EPA)
JurisdictionFederal
Chemicals~350 substances
UpdatesRarely (requires federal rulemaking)
Official Source40 CFR 355 Appendices A & B

What it is: EPCRA Section 302 identifies chemicals that are extremely hazardous to communities in the event of an accidental release. Each substance has a Threshold Planning Quantity (TPQ) — if your facility has this amount or more present at any one time, you must participate in community emergency planning.

What it means for your business:

  • If you store an EHS chemical at or above its TPQ, you must notify your Local Emergency Planning Committee (LEPC) and State Emergency Response Commission (SERC)
  • You must designate a facility emergency coordinator
  • You must participate in local emergency response planning
  • TPQ values range from 1 lb to 10,000 lbs depending on the chemical's hazard severity

7. TSCA Chemical Inventory

AuthorityU.S. Environmental Protection Agency (EPA)
JurisdictionFederal
Chemicals~86,000+ substances (but only a subset carries regulatory flags)
UpdatesOngoing
Official SourceEPA TSCA Chemical Substance Inventory

What it is: The Toxic Substances Control Act (TSCA) Inventory is the master list of all chemicals manufactured or processed in the United States. Being on the TSCA inventory means the chemical is allowed to be manufactured or imported. Chemicals NOT on the inventory may require a pre-manufacture notice (PMN) before production.

What it means for your business:

  • If you manufacture or import a chemical, verify it is on the TSCA inventory
  • Chemicals with Significant New Use Rules (SNURs) require notification before using them in new ways
  • TSCA Section 5 governs new chemical review
  • Tellus tracks TSCA flags (like SNUR designations) rather than the full 86,000-chemical inventory

8. Clean Air Act — Hazardous Air Pollutants (HAP)

AuthorityU.S. Environmental Protection Agency (EPA)
JurisdictionFederal
Chemicals~190 substances
UpdatesRarely (Congress established the original list in the 1990 Clean Air Act amendments)
Official SourceEPA HAP List

What it is: Section 112 of the Clean Air Act identifies substances that cause or may cause cancer or other serious health effects. Facilities emitting HAPs are subject to National Emission Standards for Hazardous Air Pollutants (NESHAPs) and Maximum Achievable Control Technology (MACT) requirements.

What it means for your business:

  • If your facility emits HAPs, you may be subject to emission standards
  • Major sources (10+ tons/year of one HAP or 25+ tons/year of combined HAPs) must obtain Title V operating permits
  • Area sources (below major source thresholds) may still be subject to MACT standards

9. NTP Report on Carcinogens

AuthorityNational Toxicology Program (NTP), U.S. Department of Health and Human Services
JurisdictionFederal
Chemicals~250 substances
UpdatesEvery 2-3 years (latest is the 16th edition)
Official SourceNTP Report on Carcinogens

What it is: A science-based report that classifies chemicals into two categories:

  • Known to be a human carcinogen (K): Sufficient evidence from human studies
  • Reasonably anticipated to be a human carcinogen (R): Limited evidence from human studies but sufficient evidence from animal studies

What it means for your business:

  • Carcinogens require special handling, minimized exposure, and worker notification
  • OSHA requires carcinogen-specific protections including regulated areas and medical surveillance
  • Workers must be informed they are working with carcinogens
  • Exposure records must be retained for 30 years

State Lists

10. California Proposition 65 (Safe Drinking Water and Toxic Enforcement Act)

AuthorityCalifornia Office of Environmental Health Hazard Assessment (OEHHA)
JurisdictionState of California (but affects any business selling products in CA)
Chemicals~900 substances
UpdatesQuarterly (February, May, August, November)
Official SourceOEHHA Proposition 65 List

What it is: California's landmark consumer protection law requires businesses to provide "clear and reasonable" warnings before knowingly exposing anyone to chemicals known to the state to cause cancer or reproductive harm. The list includes chemicals categorized as:

  • Cancer — known to cause cancer
  • Reproductive toxicity — known to cause birth defects or reproductive harm
  • Both — known to cause both

What it means for your business:

  • If you sell products in California or have employees in California (with 10+ employees), Prop 65 applies to you
  • Products containing listed chemicals must carry specific warning labels
  • Warnings must follow the format specified in California Code of Regulations, Title 27
  • Private enforcement (citizen lawsuits) is common — attorneys actively search for non-compliant products
  • Penalties: up to $2,500 per day per violation

Why it matters even if you're not in California: If you ship products to California consumers (including through e-commerce), Prop 65 applies. This is why Tellus includes a "Ships to California" setting in Compliance Settings.

Example warning text:

WARNING: This product can expose you to chemicals including Formaldehyde, which is known to the State of California to cause cancer. For more information go to www.P65Warnings.ca.gov.


11-14. State Right-to-Know Lists

Several states maintain their own chemical lists that go beyond federal requirements:

ListAuthorityChemicalsKey Requirement
New Jersey RTKNJ Department of Health~2,500Employers must label all containers, maintain a workplace survey of hazardous substances, and provide access to safety data sheets
Pennsylvania RTKPA Department of Labor & Industry~1,000Environmental Hazard Lists require reporting; workers have the right to know about chemicals in their workplace
Massachusetts RTKMA Department of Labor Standards~1,000Employers must report toxic or hazardous substances used in the workplace
Minnesota RTKMN Department of Labor and Industry~1,000Employee Right to Know Act requires training and information about hazardous substances

What state RTK lists mean for your business:

  • If you operate in any of these states, you have additional obligations beyond federal OSHA HazCom
  • Requirements typically include: container labeling, workplace chemical surveys, employee training, and state-specific reporting
  • The chemical lists often include substances not covered by federal regulations
  • Tellus tracks these state lists to flag which of your inventory chemicals trigger state-specific requirements

International Lists

15. IARC Carcinogen Classifications

AuthorityInternational Agency for Research on Cancer (IARC), a division of the World Health Organization (WHO)
JurisdictionInternational
Chemicals~500 agents evaluated
UpdatesOngoing (IARC publishes monographs as evaluations are completed)
Official SourceIARC Monographs — List of Classifications

What it is: IARC evaluates scientific evidence on substances, mixtures, and exposure circumstances to classify them by carcinogenic risk:

GroupClassificationMeaningAgents
1Carcinogenic to humansSufficient evidence in humans~125
2AProbably carcinogenicLimited human evidence, sufficient animal evidence~95
2BPossibly carcinogenicLimited evidence in humans and animals~320
3Not classifiableInadequate evidence~500

What it means for your business:

  • IARC Group 1 and 2A chemicals warrant the highest level of caution
  • While IARC classifications are not directly enforceable in the U.S., they inform OSHA and EPA rulemaking
  • Many IARC Group 1 chemicals are also listed under NTP, Prop 65, and OSHA carcinogen standards
  • Workers should be informed when they handle IARC-classified carcinogens

Which Lists Apply to Your Business?

Not every list is relevant to every company. Here is a guide based on business type:

Manufacturing Facilities

ListRelevant If...
OSHA PEL / NIOSH RELAlways — you have workers in contact with chemicals
EPA TRI (SARA 313)10+ employees AND in a covered NAICS code AND use above thresholds
CERCLAYou store any CERCLA-listed substance (know your RQs for spill response)
EPCRA 302You store extremely hazardous substances at or above TPQ
TSCAYou manufacture or import chemicals
CAA HAPYou have emissions of hazardous air pollutants
CA Prop 65You sell products to California consumers
State RTKYou operate in NJ, PA, MA, or MN
IARC / NTPYou use known or suspected carcinogens

Warehousing & Distribution

ListRelevant If...
OSHA PEL / NIOSH RELWorkers handle open containers or can be exposed to fumes/dusts
CERCLAAlways — you need spill response RQs
EPCRA 302You store EHS chemicals above TPQ
CA Prop 65You distribute products to California

Laboratories & Research Facilities

ListRelevant If...
OSHA PEL / NIOSH RELAlways — labs require a Chemical Hygiene Plan under OSHA 1910.1450
CERCLAAlways — know your RQs
IARC / NTPEspecially important for carcinogen handling protocols
CA Prop 65If in California or selling products derived from research

Construction & Maintenance

ListRelevant If...
OSHA PEL / NIOSH RELAlways — paints, solvents, adhesives, welding fumes
CA Prop 65Projects in California
State RTKProjects in NJ, PA, MA, or MN

Retail & Consumer Products

ListRelevant If...
CA Prop 65Critical — this is where most Prop 65 lawsuits originate
OSHA PEL / NIOSH RELWorkers using chemicals in back-of-house operations
State RTKStores in NJ, PA, MA, or MN

How Tellus Maintains Regulatory Data

Tellus uses a multi-layered approach to build and maintain accurate regulatory data for every chemical in your inventory.

Data Architecture

Regulatory data in Tellus lives in two places:

  1. ref_regulatory_list_definitions — Metadata about each of the 15 tracked lists (name, authority, jurisdiction, chemical count, last updated date, source URL)
  2. chemiq_regulatory_lists — One row per unique CAS number, with boolean flags indicating which lists that chemical appears on, plus list-specific data (TRI thresholds, CERCLA RQs, Prop 65 type, carcinogen classification, etc.)

How Data Gets Into the System

Automatic Enrichment (Real-Time)

When a new SDS (Safety Data Sheet) is uploaded and parsed, Tellus extracts the CAS numbers from the composition section (SDS Section 3). For each new CAS number, the background enrichment service automatically:

  1. Queries PubChem PUG View API — NIH's public chemical database — for regulatory information, safety data, and toxicity classifications
  2. Parses text blocks using keyword matching and regular expressions to determine which lists the chemical appears on
  3. Falls back to SDS Section 15 (Regulatory Information) when PubChem has no data — this is common for UVCB substances and petroleum mixtures
  4. Stores the results as boolean flags and metadata in the regulatory lists table

This process happens automatically within minutes of SDS upload, with no manual intervention required.

Bulk Seed Data (Periodic)

For comprehensive coverage beyond reactive enrichment, Tellus periodically seeds data from authoritative public sources:

SourceMethodChemicals
EPA TRI Chemical ListDownload from EPA public API~800
CA Prop 65 ListDownload from OEHHA public API~900
Clean Air Act HAP ListMaintained reference dataset~190
IARC ClassificationsMaintained reference dataset~500
NTP Report on CarcinogensMaintained reference dataset~250
State RTK ListsMaintained reference datasets from state agencies~2,500 unique CAS

The seed process uses upsert logic (insert or update on conflict) so it can be re-run safely whenever lists are updated.

Update Frequency

Data SourceUpdate ScheduleHow Tellus Refreshes
EPA TRI ListAnnually (January 1)Re-seed after EPA publishes annual update
CA Prop 65Quarterly (Feb, May, Aug, Nov)Re-seed after OEHHA quarterly update
IARC MonographsAs publishedRe-seed after new monographs are released
NTP ReportEvery 2-3 yearsRe-seed after new edition
OSHA PELsRarelyEnrichment picks up via PubChem
NIOSH RELsAnnuallyEnrichment picks up via PubChem
State RTK ListsAnnuallyRe-seed from state agency publications
CERCLA RQsRarelyStatic dataset, updated after federal rulemaking

How Tellus Checks Compliance

The Compliance Dashboard

The Compliance Hub dashboard provides a real-time overview of your regulatory exposure:

  • Inventory Chemicals — Total unique chemicals in your company inventory
  • Regulated Chemicals — How many of your chemicals appear on at least one regulatory list (with percentage)
  • Missing SDS — Chemicals in inventory without an associated Safety Data Sheet
  • Lists Tracked — Number of regulatory lists being monitored

A per-list breakdown shows how many of your inventory chemicals appear on each specific list, with visual bar charts for quick comparison.

Cross-Referencing Your Inventory

The "My Chemicals" view in the Compliance Hub cross-references every chemical in your company's inventory against all 15 tracked regulatory lists. For each chemical, you can see:

  • Which lists it appears on (shown as icons — green check for "not listed", red warning for "listed")
  • List-specific data (TRI thresholds, CERCLA RQs, Prop 65 type, carcinogen classification)
  • Exposure limits (OSHA PEL, NIOSH REL, NIOSH IDLH, ACGIH TLV)
  • Which products in your inventory contain this chemical and at what sites

This cross-reference is company-specific — it only shows chemicals that are actually in your inventory, not all 8,000+ chemicals in the master regulatory database.

How Each Check Works

Exposure Limit Compliance

For chemicals with OSHA PELs:

  1. Tellus retrieves the PEL value (in ppm and mg/m3) from PubChem
  2. The PEL is displayed alongside the NIOSH REL and ACGIH TLV for comparison
  3. The Action Level (50% of PEL) is calculated — monitoring is recommended when exposure may exceed the Action Level
  4. If the chemical has a substance-specific OSHA standard (29 CFR 1910.1001-1052), that is flagged separately

TRI Threshold Evaluation

For TRI-listed chemicals:

  1. The annual reporting threshold is retrieved (typically 10,000 or 25,000 lbs; lower for PBT chemicals)
  2. If your company has entered annual usage data, Tellus calculates: chemical_usage = product_annual_usage × (concentration_percent / 100)
  3. If calculated usage exceeds the threshold AND your company has 10+ employees in a covered NAICS code, TRI reporting is flagged as required
  4. The reporting deadline (July 1 of the following year) is shown

CERCLA Spill Reporting

For CERCLA-listed chemicals:

  1. The Reportable Quantity (RQ) in pounds is retrieved
  2. This RQ is displayed prominently so that anyone handling the chemical knows the spill reporting threshold
  3. If a release equals or exceeds the RQ within 24 hours, the National Response Center (1-800-424-8802) must be notified

Prop 65 Warning Requirements

For Prop 65-listed chemicals:

  1. Tellus checks your company's "Ships to California" setting
  2. If enabled, any Prop 65-listed chemical in your inventory is flagged
  3. The listing type (cancer, reproductive, or both) determines the required warning text
  4. Tellus generates the California-compliant warning text per Title 27 regulations

Carcinogen Identification

For classified carcinogens:

  1. IARC, NTP, ACGIH, and OSHA carcinogen classifications are all checked
  2. The highest-priority classification is displayed (IARC Group 1 > 2A > 2B; NTP K > R)
  3. Special handling requirements are flagged: regulated areas, medical surveillance, 30-year record retention

Progressive Compliance Checking

Tellus uses progressive checking — compliance results improve as more data becomes available:

StageWhenWhat's AvailableCompleteness
InitialAfter SDS is parsedGHS classification, CAS numbers, basic regulatory lookupsPreliminary
EnrichedAfter PubChem data arrivesExposure limits (PEL/REL), carcinogen classificationsComplete (minus usage)
Usage-BasedAfter inventory quantities are enteredAnnual usage for TRI threshold calculationsFull

Each stage re-runs the compliance checks with the newly available data, replacing previous results.


Using the Compliance Hub in Tellus

Getting Started

  1. Navigate to ChemIQ > Compliance in the sidebar
  2. Start with the Dashboard to see your overall compliance posture
  3. Use Regulatory Lists to browse all tracked lists and see which chemicals are on each one
  4. Use My Chemicals to see which of YOUR chemicals are regulated and on which lists
  5. Configure Settings to tell Tellus about your business:
    • Do you ship to California? (Enables Prop 65 tracking)
    • How many employees do you have? (Affects TRI applicability)
    • What is your NAICS code? (Determines TRI-covered industries)
    • Do you prefer NIOSH RELs over OSHA PELs? (More protective defaults)
  1. Upload your SDS documents — Tellus automatically extracts chemicals and enriches regulatory data
  2. Review the dashboard — See how many of your chemicals are regulated and on which lists
  3. Configure compliance settings — Especially "Ships to California" and employee count
  4. Review flagged chemicals — Use "My Chemicals" to identify chemicals requiring attention
  5. Take action — For each flagged chemical:
    • TRI-listed: Track annual usage and file Form R if above threshold
    • CERCLA: Post RQ values at storage locations for spill response
    • Prop 65: Ensure product warning labels are in place
    • Carcinogens: Verify special handling procedures are implemented
    • OSHA PEL: Verify exposure monitoring and engineering controls

Glossary

TermDefinition
CAS NumberChemical Abstracts Service registry number — a unique identifier for every chemical substance (e.g., 71-43-2 for benzene)
PELPermissible Exposure Limit — the maximum airborne concentration legally allowed in the workplace (set by OSHA)
RELRecommended Exposure Limit — NIOSH's recommended maximum exposure level (advisory, not legally binding)
TLVThreshold Limit Value — ACGIH's recommended exposure guideline
IDLHImmediately Dangerous to Life or Health — concentration at which workers must evacuate or use supplied-air respirators
TWATime-Weighted Average — exposure averaged over an 8-hour work shift
RQReportable Quantity — the amount of a CERCLA substance that triggers spill reporting requirements
TPQThreshold Planning Quantity — the amount of an EHS substance that triggers emergency planning requirements
PBTPersistent, Bioaccumulative, and Toxic — chemicals that persist in the environment, accumulate in organisms, and are toxic (have lower TRI thresholds)
NAICSNorth American Industry Classification System — codes that classify businesses by industry type
SDSSafety Data Sheet — the standardized 16-section document describing a chemical product's hazards, handling, and regulatory status
GHSGlobally Harmonized System — the international standard for chemical classification and labeling
LEPCLocal Emergency Planning Committee — local body responsible for chemical emergency preparedness
NRCNational Response Center — the federal point of contact for reporting chemical spills (1-800-424-8802)
Form RThe EPA form used for annual TRI reporting of toxic chemical releases