20 Days: FAQ Friday: Odds and Ends
Choice reading as you go into the weekend (or a cure for insomnia?)
I’m leaving the first 2 sections on all of the 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.
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.
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.
EPCRA SARA Hotline
And now for more FAQ
An example commonly encountered which the FAQ references are paints where the only difference between SDS’s is the color, or different blends of gasoline.
One obvious clarification in this FAQ was that different hazards would not be aggregated,
There was an interesting nuance on this one, however:
“In general, "different" mixtures are represented by different MSDSs. However, the fact that a facility has two or more MSDSs for its chemical combinations does not necessarily mean that these combinations are considered "different" mixtures. For example, if a facility receives multiple MSDSs for essentially the same material simply because the mixture is provided by different suppliers, all quantities of the mixture present at the facility must be aggregated for mixture threshold determinations.”
Note that this only applies to Hazardous Substances which are Reportable by Amount (greater than 10,000 pounds on-site at any time during the reporting year).
Extremely Hazardous Substances EHSs are by definition aggregated across all Tradenames containing that EHS for purposes of threshold determinations.
One way to accomplish the aggregation of Hazardous Substances (Reportable by Amount) operationally could be to aggregate by our old friend Part Number which is typically independent of the particular Manufacturer or Supplier.
However, if different Part Numbers exist for the same material in different sizes of containers, for example, this might not work.
Another option is to have a “Common Name” or similar field in your database/application and aggregate by that.
Clarification that the exemption comes first, and if an exemption applies, the substance is not a Hazardous Substance requiring a Safety Data Sheet SDS, henc since Extremely Hazardous Substances EHS’s are a subset of Hazardous Substances, the EHS is exempt as well.
Assume the Safety Data Sheet SDS is correct. Unless you think it’s not, in which case try to get better info.
Interesting wrinkle in this one. In addition to the usual and expected, the following is in the answer:
“In addition to these chemicals, the Hazard Communication Standard applies to any substance for which there is statistically significant evidence, based on at least one positive study conducted in accordance with established scientific principles, that indicates a health hazard as defined in 29 CFR Section 1910.1200(c).”
More tomorrow, here’s to March 2nd!
Community outreach: What other FAQs have you found useful (or just interesting)?
#SARA312 #SARATierII #SARATier2 #EPCRA #EGLE #March1EPAReportDeadline #ThresholdDeterminations #ExtremelyHazardousSubstances #EHS #ThresholdPlanningQuanitity #TPQ #EPAFAQ #CERCLAFAQ #SARAFAQ #EHSThresholdDeterminations #SARATier2EHSExemption #SARATier2RequirementforSDS
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
