5 days: Documentation around Hazards, Locations, Temperatures, Pressures
And what you didn’t report and why…
Presumably the technology that tracks your reporting will let you display all products (Tradenames) that you have flagged as Tier2 Reportable with the 2nd sort descending by what we call the Tier Reportable Amount (however you defined that, we talked a lot about different ways to do that early in this blog series).
We had 4 additional fields to identify WHY a material was Tier2 Reportable:
Reportable by Amount: Hazardous substance (needs a Safety Data Sheet) that exceeds the 10,000 pound threshold value or your local equivalent
Reportable by Extremely Hazardous Substance EHS: Material contains an EHS that has exceeded EHS Thresholds (500 pounds or the TPQ, whichever is lower, or your local equivalent). This field will get set to Yes for all materials that contain the EHS for which the material is not exempt for some other reason
Reportable by Trade Secret: Set manually
Reportable Other: You choose to report for some reason other than the previous 3. Combustible dusts or Hazardous Waste (or waste streams whether hazardous or not) might fall into this category
Now you’ll cross-reference that list to fields in your Safety Data Sheet SDS database.
You probably want to pull in/import the information you use from the SDS so that you have a “snapshot” of the information at reporting time (since SDS’s change over time).
More usefully unless you have a very robust SDS, system would be to link to an external list that you maintain independent of the SDS information, that has “Source” and “Source Description” fields to identify the source of the data.
You’ll update the SDS set of values from your SDS database/ap.
That external table will also have fields to track an alternate source of the hazard information, with the reason for the difference. A 3rd set of fields could contain the value actually used on the Tier2 report, or the 2nd field could serve that purpose.
This lets you fill in gaps from external data, show how it compares to SDS information, and decide how you want to report.
You didn;t think we’d get through an entire Tier2 reporting series without seeing the GHS Pictograms, did you?
Documenting Materials not reported
Remember that documenting why you didn’t report a material might be even more important than documenting what you report.
Sorting by Tier2 Reportable (with Yes’s appearing first) then descending by amount lets a regulator or auditor instantly see all the materials that did not exceed the 10,000 pound threshold for including Hazardous Substances (need an SDS) on your Tier2 report.
Then you’ll have another report sorting by Reportable by Extremely Hazardous Substance, that shows the sum for each CAS Number compared to its TPQ (we found it useful to display the lowest TPQ’s first). This similarly lets auditors or regulators instantly see how close an EHS was to its threshold and why it was not reported
Locations, Container Descriptions, Temperatures, Pressures:
Presumably you also have a table/database/ap that tracks all the locations for each material (Tradename).
Hopefully each location is associated with a Material Assessment Request (we called them MARS forms at Saturn) that tracks why the material was approved for use, any special conditions around approval to use, integrates with OSHA Safety activities, and has the Container Descriptions, Temperatures, and Pressures you will need for your Tier2 report.
In the best systems, the Material Approval activity is integrated with Section 302 notifications, so that when you approve purchase of a new material (change) or one that causes EHS TPQ’s to be exceeded, it will trigger notification that you need to report this activity to your LEPC and Fire Department as appropriate
And of course all of this ties into my “March 2nd (whenever it occurs)” project where I’m asking:
“How could we better display chemical hazards at a facility to firefighters and emergency responders?
What might that look like and how could we implement it?
Did I miss anything? Anything you would add?
Tomorrow we’ll be back to a few more random FAQs for the weekend, then it’s showtime!
More tomorrow, here’s to March 2nd! (it’s getting close…)
Community outreach: What has the best method of documentation of Hazards, Locations, Temperatures and Pressures been?
#SARA312 #SARATierII #SARATier2 #EPCRA #EGLE #March1EPAReportDeadline #ThresholdDeterminations #ExtremelyHazardousSubstances #EHS #ThresholdPlanningQuanitity #TPQ #EPAFAQ #CERCLAFAQ #SARAFAQ #EHSThresholdDeterminations #Documentation #DocumentingNotReportable
EPA Resources: EPA FAQ website link and the EPCRA SARA Hotline
I’m leaving the 2 key sections around getting help on any FAQ posts, how to get into the Tier2 FAQ and the EPCRA SARA Hotline number.
Remember that to Filter for Tier II Reporting only:
you will first need to check Emergency Planning and Community Right to Know on the main page,
which will give you the option to check Tier II Reporting (EPCRA 311/312),
after which you will want to uncheck Emergency Planning and Community Right to Know
so that you see 146 FAQs instead of 303 (the balance of the 303 are unrelated to 311/312)
Another non-intuitive and annoying (to me) feature of the way the FAQ’s work is that if you search, the web page unfilters before searching, so you no longer see only Tier2 FAQs. When you go back, you are still unfiltered.
So be sure to include the term Tier II in your search if you don’t want to expand the search to other (unrelated for now) topics.
I’ve provided both a link to the main (filtered) Tier2 only FAQs, and have included the hyperlinks at the bottom of each FAQ that I highlighted. So you can click those and still be looking at the appropriately filtered FAQs in a separate window if you want.
The number of results may vary as more get added
Link to EPA FAQs filtered for Tier2 only
Below is one of the most useful, where to call for help. In my experience, while you may experience some “on hold” time, the information when you get to a person will be excellent and cross referenced to the particular citations or other resources clarifying the question.
Michigan Environment, Great Lakes, and Energy EGLE links from all three 2022 SARA 312 virtual training course webinars:
I’m reposting these links with my daily Tier2 post because they are so useful.
You can sign in and watch/listen even if you didn’t sign up for the webinar series.
RECORDING LINK FOR SESSION 2: Wed Jan 19, 2022.
Really good example on batteries. This is the “in the weeds” how to conduct your threshold determinations episode: https://attendee.gotowebinar.com/recording/4027906237723673347
I talked to Mike Young, one of the presenters, right after the first webinar. He said that it’s not unusual for them to take phone calls from people from other states (with the warning to confirm that your state doesn’t have differences in their requirements compared to Michigan).
RECORDING LINK FOR SESSION 1:
https://attendee.gotowebinar.com/recording/7957790593170499843
Michigan uses Tier2 Manager for report submission, which is a Michigan-specific program. If your state uses different software, you will need to review its specific requirements.
RECORDING LINK FOR SESSION 3:
https://attendee.gotowebinar.com/recording/2763075340284995085
If your state uses a different software program there may be some differences, but this webinar will probably also cover how to determine the Hazard Ratings, how to enter Locations, and other details associated with report submission. I’ll post the replay when it becomes available.
PRESENTATION: (I wasn’t able to attach a copy of the presentation, email the link below and they will send it to you)
SARA TITLE III – TIER II REPORTING WEBSITE: http://www.michigan.gov/sara
MICHIGAN FACILITIES’ GUIDE TO SARA TITLE III: https://www.michigan.gov/documents/deq/deq-oea-saraguidebook_509720_7.pdf
CONTACT INFORMATION:
Mike Young and Adam Pohl
517-284-7272
