2 Days: Last Sunday FAQ Friday for RY2021 Tier2 Season
Back to a few serious topics as we come down to the wire…
Unlike the Toxics Release Inventory TRI report, where suppliers are required to notify customers of the presence of a TRI chemical, there is no similar requirement for 311/312.
However, just the fact that you have a Safety Data Sheet means that the material meets the definition of a Hazardous Substance. As such, it would be subject to the Reportable by Amount requirement for inclusion on the Tier2 report if the Max On Site was greater than 10,000 pounds.
There is also no corresponding requirement for notification that the Safety Data Sheet contains an Extremely Hazardous Substance EHS that I could find.
The example given is for a laboratory chemical under the direct supervision of a technically qualified individual. Since the material is exempt, it does not meet the definition of a Hazardous Substance, and so is not required to be submitted to the LEPC.
Remember that the requirement that the material be “under the direct supervision of a technically qualified individual” is a fairly stringent requirement and can be difficult to meet at all times.
Similar to the previous example, but slightly more nuanced. The exempt chemical can be excluded from the Tier2 report, but if the LEPC needs the information for Section 302 emergency planning purposes, the facility would be required to provide the information
Going one step further, for an exempt chemical, the exemption still applies and the SDS would not be required to be submitted to the public upon request.
More tomorrow, here’s to March 2nd! (3…2…1…almost to zero)
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 #SARATier2FAQ #SDSSuppliernotification#SupplierNotification #LEPCRequestExempt #ExemptChemicals #PublicRequest
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
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
