26 Days: More FAQ Friday
Selected FAQs, from the useful to the obscure to the just plain interesting
I’m leaving the following 2 sections on all of the FAQ posts, how to get into the Tier2 FAQ and the EPCRA SARA Hotline number.
Searching FAQs to select for Tier2 only: While it shows 303 FAQs when you filter for EPCRA and its subcategory Tier II Reporting (EPCRA 311/312), (which you don’t see until you check the Emergency Planning and Community Right to Know checkbox), if you unselect EPCRA and only leave the Tier II Reporting (EPCRA 311/312) checkbox clicked, you get 146 FAQs instead of 303. I wondered why so many of the FAQs at the end related to release reporting…
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.
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.
Link to EPA FAQs filtered for Tier2 only
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)
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 resources
Are there extensions to the deadline? In a word, no. If you want to know why, read the above FAQ.
And if March 1 falls on a weekend? Unlike your taxes, the Tier2 report must be postmarked/submitted by March 1 irrespective of whether that date falls on a weekend
EPA FAQ clarification of the extent to which researching CAS numbers for validity is required. EPA recognizes that CAS Numbers may be invalid on the SDS and so not pass the CAS Number validation in the Tier2 Submit software. Try for better information, if not available, this FAQ gives you the option to leave the CAS Number blank. Obviously, that would not apply to Extremely Hazardous Substances EHS, where you need to know the CAS Number to know that it is an EHS.
This one about contractors was not obvious and was different from what i have heard in the past. Check with your regulating authority.
And the above just for fun trivia.
That’s it for FAQs for today, a few more tomorrow. We’ll do a separate post around non-reactive solids, which have several FAQs..
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 #SARATier2WeekendDeadline #SARATier2ExtensionOption
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
