30 Days: Halfway home! And we’re finally doing Threshold Determinations
Hard to believe we spent the first half of our Tier2 Reporting time doing data collection and cleanup…
Or not. The good news is that all the work we’ve put in will not only stand us in good stead for Tier2 reporting, but also for Toxics Release Inventory TRI reporting, and for other regulatory reports around our chemical usage.
I found this amusing…it must be Tier2 reporting time!
The other piece of good news is that Threshold determinations are a fairly straightforward and simple process. (Notice I didn’t say easy, that depends on what tools are available to you)
A note about the approach. You have the option to report by SDS’s or by CAS Numbers, the choice is yours. You need to be consistent with how you submitted your 311 notifications, but you can do a one time change to go from one reporting method to the other.
I’ve heard that the preference is for reporting by Safety Data Sheet SDS, since that’s more useful for the emergency responders, which is who this report is designed to protect. So the steps here will assume you’ll be reporting by Safety Data Sheet SDS.
Here are the steps to conduct the first draft of your Threshold Determinations to determine what needs to be included on the TIer2 report:
Compare your Max On Hand Amounts (the total amount for the SDS, not the CAS components) against 10,000 pounds or your local regulatory equivalent. Anything that exceeds that amount is reportable unless exemptions or other special cases apply. Done. These will be included on your Tier2 report.
Compare your Sum by CAS Number totals to the Extremely Hazardous Substance CAS Numbers. For anything that’s a match, compare to the lower Threshold Planning Quantity or 500 Pounds, whichever is lower. In this case, if the CAS total exceeds the lower of those two numbers, every SDS that contains that CAS number will be included on your Tier2 report
Today we’re talking about the first draft of the threshold determinations. At the end of this process, you definitively know everything that’s NOT going to be included on your Tier2 report.
Over the rest of the week we’ll talk about exemptions, when you can use the Upper TPQ instead of the lower one, and other ways that items might come off the Tier2 report, and other special cases.
That’s it! Now to start refining this list…
More tomorrow, here’s to March 2nd!
Community outreach: How many items appear on your Tier2 report?
#SARA312 #SARATierII #SARATier2 #EPCRA #EGLE #March1EPAReportDeadline #ThresholdDeterminations #ExtremelyHazardousSubstances #EHS #ThresholdPlanningQuanitity #TPQ
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
