31 Days: Verifying the CAS Numbers you compare for Extremely Hazardous Substances EHS’s
The last step before we go on to Threshold Determinations!
There are just a few steps you will need to take with this list so that it matches up to your CAS Numbers and so that you can compare against Upper and Lower Threshold Planning Quantities TPQ’s in your Threshold Determinations
I found this amusing…it must be Tier2 reporting time!
More relevant to our purposes,
Here’s a link to the page with all the variations of the EPA List of Lists.
You’ve already seen snippets of this list in our SDS Ambigous CAS Number cleanup examples for Sulfuric Acid and Phenol. Here’s a different segment of the list.
If you’re lucky, you have a regulatory update service that provides you with this list in structured format that you can directly compare your Max On Site (Starting Inventory + Total Annual Purchases) CAS Number amounts against.
If’ that’s the case, confirm that the version in your regulatory update service is the appropriate one. For RY 2021, that is the version of the list published in Sept 2021
If you need to improvise from the Excel list, here are a few considerations. These are probably obvious, and you may have better ways of accomplishing these activities. (If you do, please share in the comments!):
Filter out everything that’s not in the Sec 302 (EHS) TPQ column. One way to do this is to sort the entire Excel descending by values in the Section 302 (EHS) TPA column then deleting everything below it that’s blank. If you want the list to import in the same order as the Excel, after you delete the non-EHS CAS Numbers, re-sort by the 1st column, Name, before importing/further processing
Since you need an Upper TPQ and a Lower TPQ, copy the column that has all the TPQ values into 2 more columns, sort for everything that has a slash in it / indicating there is both a Lower and an Upper TPQ for those chemicals, edit the value so the Lower TPQ is in the first of your copied columns and the Upper TPQ is in the second one
You’ll need a way to have the format of the CAS Numbers match up between your Max On Site CAS Amounts and the EHS list. This might be automatic or might take some manipulation on your part.
That’s it! On to threshold determinations…
More tomorrow, here’s to March 2nd!
Community outreach: How are you able to compare the EHS CAS Numbers to your Max On Site CAS Amounts? What tools do you have available to you?
#SARA312 #SARATierII #SARATier2 #EPCRA #EGLE #March1EPAReportDeadline #ThresholdDeterminations
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
