22 Days: Hazards, more on
How do you track the source of your data?
Here’s the official “crosswalk” from old to new hazards. I find it interesting that the order is different for the new hazards than for the old ones:?
For substances that are only Reportable by Amount (Max Onsite Greater Than 10,000 pounds at any time during the year), the hazards would come directly from the Safety Data Sheet SDS..
Even that might not be as easy or intuitive as it sounds. Paraphrasing the EPA’s Q&A from yesterday’s post, here’s what to do if you’re having trouble getting the hazard information:
Try to get a better Safety Data Sheet SDS from your SDS provider
If hazards for current SDS are different from the old one for a reportable chemical, assume the new one is correct
Two similar chemicals, different manufacturers, show different hazards? If you reported them before, report the same way you did in the past. If newly reportable chemicals, report the same hazards for both OR submit data sheets with a letter of explanation
Can’t get a current SDS (example is 15 year old SDS and manufacturer out of business)(and you’re still using it? Where are you getting it from? But I know there are examples where you can’t get a current SDS). OK to use the crosswalk to determine the new hazards based on the ones you reported in the past
Where do you find the Hazard Information on the Safety Data Sheet SDS?
Theoretically, Section 2 of the Safety Data Sheet should provide the Hazard information you will need for your Tier2 report.
Go start/continue checking out the caliber of the hazard information on your Safety Data Sheets SDS’s and we’ll check back in tomorrow to see what the quality of this information was and alternatives if it was deficient, and after that we’ll start looking at hazards for materials containing Extremely Hazardous Substances EHSs.
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: What SDS’s were missing (usable) Hazard information in Section 2? What work-arounds did you use to obtain the needed information?
#SARA312 #SARATierII #SARATier2 #EPCRA #EGLE #March1EPAReportDeadline #Hazards #GHS #Crosswalk #SDS #SDSSection2
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
