12 Days: Another Saturday FAQ Friday-Medical and Research Part 1 of 2
Counting down…
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.
Book for the day is Managing the Unexpected, about what High Reliability Organizations HRO’s (which include medical personnel and emergency responders) do differently from the rest of us and how we can learn from them.
One of my presentation topics is “Error Proofing for Fatigue and other Cognitive Impairments”. Did you know OSHA has a web section specifically around fatigue? Check out Chapter 5 in Margaret Heffernan’s (also excellent!) book Willful Blindness about the Texas BP Oil Refinery explosion and the role fatigue played in that incident.
(Both books are terrific as audiobooks, Margaret Heffernan narrates her book and has a droll British voice. I know I said you have time, but maybe not enough to read paper).
And now on to a few more FAQs…We’ll do 2 days of FAQs around Medical and Research since there are quite a few of them
This FAQ covers the finer points about what activities are exempted and what are included across medical facilities and research laboratories (including veterinary facilities).
This FAQ distinguishes between chemicals used for medical or research purposes and chemicals used at medical or research facilities but not for medical treatment or research (“that serve an ancillary function”).
In all cases the exemption from the defiinition of a Hazardous Substance (requiring a Safety Data Sheet) specifies that the chemical must be used “under the direct supervision of a technically qualified individual”.
This FAQ is an extension of the one above it and clarifies the definition of a “technically qualified person”.
It also clarifies that the storage tank for the Oxygen is also exempt, since the oxygen in it is used only for treating patients. In the previous FAQ where Liquid Nitrogen is the example, the FAQ clarifies that only the Nitrogen used for treating patients is exempt; any other uses non-medical or non-research related would not be exempt.
And our “off the wall” FAQ for the day is around Animal Digestors or Incinerators.
But this FAQ meaningfully clarifies the definition of a facility and the extent to which equipment used for medical purposes at such a facility is exempt.
This FAQ again reiterates the requirement that “its administration is carried out under the direct supervision of medical professionals (e.g., doctors, veterinarians)” in order for the exemption to apply
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
