34 Days: Ambiguous SDS constituents, cleanup before threshold determinations, part 1 of 3
This is the big one that connects the dots…SDS Constituents to Constituents where you’re deciding it’s OK if they don’t match to a “real” CAS Number, and CAS Numbers that you’ll be able to use for threshold determinations
So Safety Data Sheets SDSs come in with the CAS Number associated with constituents all over the map in terms of what is entered. This is as compared to “real” Chemical Abstract Services CAS Numbers, the unique (US) identification for chemical identity (see the report snippet below for a few of these—.Not Provided, Multiple, N/A, Mixture, and Non-Hazardous just in this short segment of the report).
So how do you figure out which of these matter in terms of threshold determinations? And can you set it up so you don’t have to revisit the same ambiguous chemicals year after year? Stay tuned…
Connecting the dots from ambiguous Constituents to CAS Numbers that can be usedd for threshold determinations is just a few steps away…
Safety Data Sheet Ambiguous Constituent Cleanup:
Yesterday you created a query/report that shows your on-site amounts descending by the Maximum Total Amount On-Site (sum of Starting Inventory (if you have one) + Purchases (Receipts), with all the consituents listed for each of those SDS Numbers (see below).
Re-run that now that you’ve cleaned up your SDS’s to obtain missing consitituents and have assigned Numeric Percentages to each constituent
On this snippet that we saw in a previous post, note the various non-valid (text) CAS Numbers. In this post we’ll figure out which ones are ok that way, which ones to fix, and how to not have to do it for the same constituents next year.
3. Now Sort the report by Constituent Name, with Constituent Amount (Total SDS Amount x NumPct x .01) descending by Consituent Amount the next sort, and showing the CAS Number. This report also shows the total purchases for each CICN (our Safety Data Sheet SDS Number, it stands for Chemical Inventory Control Number) in addition to the Constituent Amount, and all other things being equal that field is sorted descending by amount also. This way bigger contributors appear first..
This will group constituents with ambiguous CAS Numbers adjacent to the same Constituent with a valid CAS Number.
This data still gives you the Safety Data Sheet Number so you can go back and edit the data at the source if you get better information.
Here you see that Perfluoro compounds has the same CAS Number as Perfluorochemical, so they will be added together for threshold determinations. The next two? You might want to check
SDS 5168 for the MIXTURE CAS Number would be a good one to investigate. Since it’s Constituent Amount,is 304.3 pounds, if it was an Extremely Hazardous Substance EHS (which it’s not), it would be getting us close to that 500 pounds or the Threshold Planning Quantity TPQ whichever is less. Looking at it, since we know it’s not an EHS (unless your state has mandated it), we would proiritize it lower down the list for research and followup.
And SDS 7261 for the N/P which stands for Not Provided CAS Number, at only .1 pounds for the Constituent Amount, we would probably ignore, again since it’s not an EHS. Unless you have the luxury of doing 100% cleanup, in which case go for it!
4. You will also see variations, both good and bad, of different CAS Numbers for the same constituent.
For “bad” CAS Number variations of CAS Numbers that appear to be real (have the correct format), we’ve seen transposed (reversed) digits, missing digits, added digits, “nearby digits” (typos) and probably several others. This data has already been cleaned up, so you won’t see actual “bad” CAS Numbers (ones that don’t satisfy the CAS Number algorithm).
Since the algorithmically bad CAS Numbers will appear adjacent to the valid one, you get a hint of what the correct CAS Number might be and can follow up accordingly
You’ll also see all of the text CAS Number like MIXTURE and N/P in the above example, and they will appear adjacent to the good CAS Numbers. If appropriate you can change them (a call to the SDS author to confirm this is ok would be good, getting a corrected SDS from them would be better).
With the format above, you’ll see all those bad versions side by side (when you see them side by side, which you will in the above format) in this example
An example of “good” (meet the check digit algorithm) CAS Numbers that may be confusing include “generic” CAS Numbers for which more detailed CAS Numbers exist (see example below)
Multiple CAS Numbers that might all appear on an SDS with the Constituent Name “Aliphatic Hydrocarbons”
Note that for purposes of Extremely Hazardous Substances EHS threshold determinations, only CAS Numbers that are an exact match with the CAS Number on the EPA List of Lists (link to the Sept 2021 version, you can download it in Excel at this link. There’s also a pdf document of changes that addresses perfluoro compounds and the Toxics Release Inventory TRI report that you will want to review)
For Reportable by Amount threshold determinations (Hazardous Substances, which are materials for which you have a Safety Data Sheet SDS and for which 10,000 pounds is present on-site at any time during the reporting year), we use the Safety Data Sheet amount as a whole (your system may handle this differently).
5 We have a field in the Constituent Master file for NoCASNumOK, that is, whether it is ok that this CAS Number Constituent name does not have a valid CAS Number. Below you will see an example of that table
Here you see where the entries below the first one are OK without a CAS Number.
The first constituent should probably have the CAS Number on the SDS Constituent changed to the for Lead (probably) or Lead Oxide (less regulated and it’s a Lead Compound) or have a constituent entered for both (most conservative) if better information has not been obtained from the SDS Supplier. Confirmation with the SDS provider would be good, an updated SDS showing the corrected information would be better.
6. The ap we used automatically added records to the CAS Number master table if they didn’t already exist but only if the CAS Number satisfied the CAS Number algorithm, or you may have a CAS Number master table provided to you.
When you conduct threshold determinations, only constituents with valid CAS Numbers will be included. The Constituent Name (synonym) will be ignored.
And only Constituents where the CAS Number matches the CAS Number on the EPA List of Lists LoL will be included in the Extremely Hazardous Substance EHS threshold determination. This is a reason to verify the CAS Numbers if you have a chemical name that appears on the EPA LoL EHS but for which the CAS Number is not a match.
This is such an interesting (and tricky) topic that I’m going to divert from my “weekend in the weeds” database posts this weekend and include a couple of other examples of a couple of different ways the Constituents and CAS Numbers might appear in your data, and what to do about them.
More tomorrow, here’s to March 2nd!
Community outreach: How have you managed ambiguous CAS Numbers?
#SARA312 #SARATierII #SARATier2 #EPCRA #EGLE #March1EPAReportDeadline #ThresholdDeterminations #CASNumbers #BadCASNumbers #ConstituentCleanup
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
