Plain answer

A Hazardous Materials Inventory Statement identifies hazardous materials, hazard classes, quantities, physical states, and storage or use conditions. A Hazardous Materials Management Plan shows where and how those materials are stored, used, controlled, and accessed. The authority having jurisdiction decides whether one or both are required and what format it will accept.

HMIS and HMMP side by side

The two documents answer different but connected questions. The inventory supplies the quantities and classifications; the plan connects those quantities to rooms, control areas, systems, and emergency features.

HMISHMMP
PurposeIdentify and classify hazardous-material inventoryMap how and where hazardous materials are managed
Core contentsChemical identity, concentration, hazard class, physical state, container, maximum quantity, storage or use conditionSite and floor plans, control areas, storage and use locations, tanks, piping, access, protection and spill-control features
IFC basisSections 407.5 and 5001.5.2; Appendix H Section H102 format where adoptedSections 407.6 and 5001.5.1; Appendix H Section H101 format where adopted
Primary reviewerFire code official, often coordinated with building plan reviewFire code official, often coordinated with the architect and fire-protection engineer
Update triggerInventory, quantity, location, process, ownership, permit, or local annual-update requirementLayout, control-area, equipment, storage, use, access, protection, or permit change

What triggers the submittal?

The presence of hazardous materials does not automatically require both documents. The usual triggers are a hazardous-materials operational permit, a construction permit for a regulated installation or substantial modification, or a direct request from the fire code official under Sections 407.5 and 407.6.

Phoenix Section 105.5.22 requires an operational permit when hazardous materials exceed the quantities in Table 105.5.22. Section 105.6.13 requires a construction permit for specified installations and substantial modifications above those quantities, including storage facilities, tanks, gas cabinets, exhausted enclosures, gas rooms, and chemical drainage and containment areas. When an HMIS or HMMP is required, omitting it from the permit package can stop plan review or permit issuance.

Code basis and the Appendix H caveat

International Fire Code Sections 407.5 and 407.6 establish the Hazardous Materials Inventory Statement and Hazardous Materials Management Plan submittals where required by the fire code official. Sections 5001.5.1 and 5001.5.2 connect those documents to hazardous-material permit applications. Appendix H then supplies format instructions, with H101 addressing the HMMP and H102 addressing the HMIS.

Appendix H is not automatically mandatory. An IFC appendix has force only when the adopting jurisdiction specifically adopts or references it. A facility can therefore owe an HMIS under Section 407.5 even when the Appendix H format is not locally binding. That is one reason local spreadsheets, portals, drawing standards, and terminology vary.

Can a Tier II report serve as the HMIS?

Sometimes, but do not assume it. Phoenix's amended Section 5001.5.2 begins: “Where required by the fire code official, an application for a permit shall include a Globally Harmonized System of Classification and Labeling of Chemicals.” It then lists an HMIS, SARA Title III Tier II report, or other approved statement as alternatives.

Phoenix Fire Prevention's current explanatory policy is narrower in practice: it directs chemical-inventory reports through the department's HMIS form and intake process and says HMIS submissions in other formats will not fulfill its submittal requirements. The defensible reading is that the code text permits Tier II or another approved statement, while the department's current intake policy expects its own HMIS form. Confirm approval with Phoenix Fire Prevention before relying on Tier II alone.

Why Tier II is not an MAQ worksheet

Even where the fire code official accepts a Tier II report as an inventory statement, the federal form does not supply the complete dataset needed for a maximum allowable quantity analysis.

Tier II coverage begins with chemicals for which an Occupational Safety and Health Administration safety data sheet is required and then applies reporting thresholds. The general threshold is 10,000 pounds. For an extremely hazardous substance, the trigger is its threshold planning quantity or 500 pounds, whichever is lower. Section 370.13 also excludes categories the fire code does not generally exclude, including a substance used in a research laboratory under the direct supervision of a technically qualified individual.

Tier II reports the maximum amount using a range code rather than an actual quantity and describes the prior calendar year's inventory. Its hazard fields are Hazard Communication physical- and health-hazard categories, not International Fire Code hazard classes. It also does not divide each quantity among storage, closed-system use, and open-system use. Those distinctions, together with current or proposed maximum quantities and control-area locations, are central to the fire-code calculation.

  • Tier II maximum: a reporting range, not the actual design quantity
  • Tier II scope: limited by Safety Data Sheet coverage, thresholds, and EPCRA exemptions
  • HMIS classification: International Fire Code hazard class and physical state
  • HMIS quantity split: storage, closed-system use, and open-system use
  • HMIS geography: each control area or Group H occupancy
  • HMIS timing: current or proposed maximum onsite quantity

How an inventory becomes a building-design issue

The design team assigns each material to its International Fire Code hazard class, physical state, and storage or use condition, then compares the total in each control area with Tables 5003.1.1(1) through 5003.1.1(4). Table footnotes allow specified increases for features such as an approved automatic sprinkler system or approved storage cabinets, but only when the stated conditions are met.

Table 5003.8.3.2 limits the number of control areas on each story and the percentage of the base maximum allowable quantity available to each. When a quantity exceeds the applicable maximum allowable quantity, International Building Code Section 307 generally moves that portion of the building into a Group H classification unless an exception applies. That decision can change construction type, fire-resistance separations, exhaust and gas-detection systems, and other building features. An inventory error can therefore become a building-design error.

A Phoenix trigger for semiconductor facilities

Phoenix carries a standalone operational permit in Section 105.5.58.20 for a semiconductor facility that is not part of a hazardous production materials facility. Semiconductor fabrication facilities and comparable research and development areas classified as Group H-5 fall within Chapter 27. Semiconductor operators should resolve that HPM split early because it affects the permit path and the systems, plans, and inventory analysis expected by the city.

Which one is required in Arizona?

The correct answer depends on the address and the fire authority, not merely the county name. The following examples show why local-style searches such as ‘HMMP Chandler AZ’ should lead to an authority check rather than a generic form.

JurisdictionCurrent code and local directionAppendix H status or practical effect
PhoenixThe 2024 Phoenix Fire Code took effect February 17, 2026. The amended Section 5001.5.2 lists GHS documentation, an HMIS, a Tier II report, or another approved statement, while Fire Prevention's current policy directs HMIS submissions through its department form and intake process.Appendix H is adopted, but Phoenix Fire Prevention also runs its own HMIS form and intake process. Use the department's form rather than building your own from the Appendix H figures.
Chandler2024 IFC with city amendments. Chandler added Section 5001.5.3 authorizing electronic HMMP and HMIS filing and requiring an approved copy onsite.Confirm the accepted form and drawing package with Chandler. The local amendment controls electronic filing but does not itself substitute Appendix H instructions for AHJ approval.
MesaMesa's 2024 IFC took effect January 8, 2026. Mesa publishes a local HMIS worksheet among its construction forms.Use Mesa's current worksheet and confirm whether an HMMP drawing is also required. The published local resource is more actionable than assuming the model Appendix H form.
TucsonTucson applies the 2018 IFC with local amendments. Its adopting amendment packet expressly adopts Appendix H.Use adopted Appendix H as the starting point, then confirm the current HMIS or HMMP format and intake procedure with Tucson Fire before submittal.
Unincorporated Maricopa CountyThere is no single countywide private-facility fire-code answer. The applicable city, fire district, or state fire authority can control. The county's 2003 IFC adoption is limited to county-owned facilities.Identify the actual fire authority first. Appendix and form requirements depend on that authority, not the words ‘Maricopa County’ in the mailing address.

Submission checklist

Resolve the local rules before building the workbook or plans.

  • Confirm the adopted code edition and local amendments
  • Obtain the authority's current HMIS template or portal instructions
  • Ask whether an HMMP, site plan, floor plan, or professional seal is required
  • Confirm whether the AHJ accepts a Tier II report in place of a jurisdiction-specific HMIS form
  • Reconcile the HMIS, HMMP, architectural plans, and actual field conditions
  • Coordinate inventory changes with the architect and fire-protection engineer

Why the two documents must agree

An accurate inventory with an outdated floor plan can place materials in the wrong control area. A detailed drawing with incomplete quantities can produce the wrong occupancy classification. The HMIS, HMMP, architectural plans, and actual field conditions should describe the same facility.

Need a facility-specific answer?

ACP can connect the rule to the chemicals, equipment, records, and operating conditions at your facility.

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Primary references

Confirm requirements against the current regulation, adopted code edition, authorized state program, and local agency procedures.