32 Days: Ambiguous SDS constituents, multiple CAS Numbers same Constituent: Phenol example
Here’s another example of Constituent cleanup and CAS Number resolution
In this example, note the multiple different CAS Numbers that are valid CAS Numbers that all have a Constituent Synonym of “Phenol”.
If we look at the EPA List of Lists, we see that Phenol in the Section 302 (EHS) TPQ column only lists CAS Number 108-95-2
(Also note that it has 2 TPQ’s. Remember the upper TPQ is for non-reactive solids in solution and non-reactive molten solids. Again, we’ll do the first threshold determination against the lower number, then take the higher value exemption if it applies only if it would make a difference in whether we report or what we report).
So what’s the story on the other 2 CAS Numbers listed as Phenol?
If we search for the first one, we find that CAS Number 143-74-8 is for Phenol Red, also known as Phenophthalein, an indicator chemical you might remember from chemistry class.
Search for the CAS Number readily yielded results
Remember this from chemistry class?
A similar search for CAS Number 25338-55-0 also yielded results:
So while the results are a little confusing, they’re valid.
You might want to go edit the SDS Constituents and/or reach out to the SDS Supplier for a clearer version so you don’t have to look at this again next year.
If we look more comprehensively at the entry that showed “Phenol, polymer with formaldehyde” we see that when we expand the constituent name it is clearly not phenol. Here I was also looking for whether I needed a Formaldehyde constituent for the Toxics Release Inventory TRI or other report, clearly I don’t.
And at 0.4 pounds total, and only .1 pounds for the constituent, it would not have been a big concern in any case.
Just to be thorough, I took a look at the Phenolic Resin #4. This one would require a call to the SDS provider to get any further info. For TRI purposes, some resins off-gas when they are being processed, but again at only 3.6 pounds total, probably not a big concern.
So there you have a couple of examples over the last couple of days!
Remember that when you conduct threshold determinations, only constituents with valid CAS Numbers will be included, and only CAS Numbers that are a match for the CAS Number in the EPA List of Lists Section 302 (EHS) TPQ column will be included in Reportable by EHS threshold determination calculations.
The Constituent Name (synonym) will be ignored.
More tomorrow, here’s to March 2nd!
Community outreach: What other interesting special cases have you encountered for ambiguous CAS Numbers?
#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
