11 Days: Another Sunday FAQ Friday - Medical and Research FAQs - Part 2 of 2
Counting down…
(You’ll need to search for the Link to Atul Gawande’s web page for Checklist Manifesto, it’s not a secure site)
I again/still have the illusion that with the resources you’ve been getting in these blog posts, you might have time to start thinking forward.
My book suggestion for today is Checklist Manifesto by Atul Gawande.
It’s a good followup to yesterday’s recommendation Managing the Unexpected, which highlights what High Reliability Organizations HRO’s, of which medical entities are a part, do differently from non-HROs .
And Checklist Manifesto as a book selection is consistent with our medical theme because many of the examples are around using checklists at medical facilities, highlighting some dramatically improved results as a result of checklist use.
The content is local to me, since some of the studies were done at the University of Michigan Medical Center in Ann Arbor, just a half hour south of my horse farm..
And now on to a few more FAQs. This is the second of 2 days of FAQs around Medical and Research topics.
This FAQ provides the most detailed description of what the term “technically qualified individual”, and clarifies which chemicals are exempted and which are not
Similar to the previous FAQ, this one emphasizes “under the direct supervision of a technically qualified individual”, and clarifies which activities and chemicals are not exempt..
This FAQ is very specific to the medical activities associated at a pharmaceutical pilot plant as described in the text of the question (and is different from the interpretation of pilot plant applicability for Toxic Release Inventory TRI calculations)..
This FAQ provides clarification about the conditions under which FDA regulated chemicals are exempt.
No humorous one today, sorry.
More tomorrow, here’s to March 2nd!
If you need help finishing up your Tier2 activities, feel free to reach out to me at manguardehs at gmail dot com
Community outreach: Do the medical or research facility exemptions apply to your operations?
#SARA312 #SARATierII #SARATier2 #EPCRA #EGLE #March1EPAReportDeadline #ThresholdDeterminations #ExtremelyHazardousSubstances #EHS #ThresholdPlanningQuanitity #TPQ #EPAFAQ #CERCLAFAQ #SARAFAQ #EHSThresholdDeterminations #SARATier2FAQ #HazardousSubstances #MedicalExemption #ResearchExemption #LiquidNitrogen #Oxygen #Veterinary #AnimalDigestor #AnimalIncinerator #MedicalIncinerator
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
