13 Days: Another FAQ Friday
Counting down…
As we go into the home stretch, I will start to wax philosophical about how your Tier2 reporting period might go better next year.
This is one of my favorite resources, I’ve linked to the website of the author, who it appears has put out other resources that I’ll need to check out.
One of his concepts is to “questionstorm” instead of brainstorm. How might that be a concept that could improve your EHS processes?
And now on to a few more FAQs…
Reporting hydrofluoric acid as a mixture
This FAQ is similar to our Ammonia/Ammonium Hydroxide example we did on Day 29 when we were considering exemptions and Extremely Hazardous Substances EHSs.
But it’s a concept there are frequently questions about, so I thought it wouldn’t hurt to include it again.
Remember that you need to report consistently, either all and only by CAS Number, or all and only by mixture (Tradename) (even though you will have calculated the Extremely Hazardous Substance EHS thresholds based on CAS Number)
I always thought the mixture method of reporting was more useful to the firefighters and emergency responders this report is geared towards, even though it adds the extra step of figuring out all the mixtures/tradenames that contain any reportable EHS’s.
Makes sense, if it didn’t make it on-site, it’s not reportable for Tier2.
Purchases can be a good surrogate for the amount of material on-site, albeit a little bit of ahead of when purchases would arrive at the facility.
The best practice I know of was to report to the LEPC when the amount approved for purchase would exceed the Threshold Planning Quantity for a material not otherwise exceeding the Extremely Hazardous Substance threshold or the 10,000 pound reporting liimit for Hazardous Materials (need a Safety Data Sheet).
Using invoices as a proxy for the amount of material is another option, this one is more reliable with respect to the material actually having arrived on-site (facilities seldom pay for materials not delivered), but is a lagging indicator depending on how long before the transaction appears in the invoice file. If you can get it based on Receipt Date, it’s a pretty accurate measure. Invoice payment date can be significantly delayed and is not as good an option.
Given that this FAQ was last updated Sept 2021, it certainly waffles a bit. Here’s the link to the actual matrix of state requirements that is on the EPA website (their link just takes you to the main EPA EPCRA page)
Oops, I said we’d into how to determine whether a constituent is a carcinogen today, look for that on Monday
Sorry about that, you still need to report the following March 1 for the previous reporting year. Doesn’t seem very useful, but there it is.
And our amusing one for the day, personal use of e-cigarettes is exempt but the chemicals used to manufacture them are not. If you want an eye-opener, check the ingredients. I remember seeing those for regular cigarettes in conjunction with some consulting a long time ago.
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: Have you removed constituents from consideration for Tier2 reporting based on De Minimis concentrations? Which ones?
#SARA312 #SARATierII #SARATier2 #EPCRA #EGLE #March1EPAReportDeadline #ThresholdDeterminations #ExtremelyHazardousSubstances #EHS #ThresholdPlanningQuanitity #TPQ #EPAFAQ #CERCLAFAQ #SARAFAQ #EHSThresholdDeterminations #SARATier2FAQ #HazardousSubstances #HydrofluoricAcid #HF #PurchasedNotReceived #FacilityClosed #StateRequirements #e-cigarettes
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
