36 Days: SDS constituent cleanup before threshold determinations, part 1
Now the fun begins! (if you’re a geek like me)
Ideally you would clean up every Safety Data Sheet SDS for which the material was on-site before conducting your Tier2 Threshold Determinations. And maybe you still can. But hey, it’s 37 days until the report is due. So let’s see if we can do some intelligent prioritization…
We’ll default worst case if information is missing. If that most conservative case doesn’t cause the material to be reportable, you have until Toxics Release Inventory TRI or your next report to get better information.
There are small cleanups and large ones. Hopefully your data cleanup requirements are small.
Safety Data Sheet Constituent Cleanup Suggested Steps:
Create 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). Tank maximums would be part of your starting inventory, or a separate item if you don’t have a starting inventory. our attention to Purchases + Starting Inventory amounts.
Associate all the constituent percentages with each Safety Data Sheet and show the amounts, again descending by constituent amount, as lineitems associated with that SDS amount. An example may be useful here
Report descending by the sum of the total amount received showing the constituents that contributed to that sum, descending by constituent amount. Note the Not Provided, Multiple, N/A, Mixture, and Non-Hazardous for CAS Numbers. We will resolve those in a later post.
3. Now cleanup SDS Constituent information by resolving the following:
SDS’s for which you had material on-site last year for which there are no Constituents associated with the SDS. You have no way of knowing whether these contain Extremely Hazardous Substances that might be reportable if present in other materials at the facility. If the Manufacturer or Supplier will not provide constituents, ask them for an email stating that the material does not contain any Extremely Hazardous Substances, and include that in your documentation. In some cases the constituent information on the SDS (section 3) does not list a substance but it is called out in the regulatory section of the SDS (section 15).
Reference to another SDS in lieu of constituents. We have encountered situations where data entry personnel entered something like “See SDS 12345” for a constituent instead of re-entering constituents or entered “Like SDS 12345” where 12345 is a different (usually newer) SDS. If you encounter these situations you will need to enter the constituents for the SDS that corresponds to the material you had on-site during the reporting year
In some cases a generic CAS Number gets assigned to a group of constituents, each of which have their own CAS numbers, some of which may be reportable. Gasoline for the Toxics Release Inventory TRI report is the most prominent of these. There is a single CAS Number for Gasoline 8006-61-9, but gasoline consists of a number of constituents (see below). If you are aware of situations like this, you will want to enter the actual CAS Numbers that might be reportable, with notes to exempt the generic CAS Number constituent so that it is not double-counted
Gasoline constituents showing individual CAS Numbers
Check for duplicate CAS Numbers on the same SDS. In some cases that is the actual information that appears on the SDS, frequently however it is a data entry error
4. Now add up all the Constituents for each SDS and run a report of all SDS’s where the sum of the constituent percents is zero.
Since you already resolved SDS’s that had no constituents, these would be SDS’s where a constituent was named but no percentage was provided. We created a Numeric Percent field in the database which is where the value for the constituent that would be used for threshold determinations would be entered, along with a reason why that was the number. (This field will also be used to capture the results of Greater Than, Less Than, Balance, and Range constituents which we will cover in tomorrow’s post).
You can put 100 in this Numeric Percent field for any constituent percentages that are zero or blank. This is the most conservative assumption (worst case), since if there are 10 constituents, all 10 would be entered at 100 percent. If you run your threshold determinations using these high numbers and still don’t exceed your EHS thresholds, you can get better information on March 2nd (in time for TRI reporting)
5. Run another report that shows the sum of Constituent amounts descending by the sum. Anything less than 100, you will probably need to get better information, since in this case it is likely that you are missing constituents. Again, if the manufacturer or supplier won’t provide the missing information, request an email stating that there are no EHS’s.
Is that enough for one day? Tomorrow we’ll take on Greater Than, Less Than, Balance, and Range when provided on an SDS
Community outreach: What other special cases of bad constituent data have you encountered?
#SARA312 #SARATierII #SARATier2 #EPCRA #EGLE #March1EPAReportDeadline #ThresholdDeterminations
Today is the 3rd and last of the Michigan Environment, Great Lakes and Energy EGLE EPCRA SARA Tier2 webinars, this one around filling out the Tier2 Submit Software.
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.
Michigan EGLE links from first and second webinars of 2022 SARA 312 virtual training courses:
I’m keeping these links for awhile because they are so useful.I’ll post the session 3 recording info when it becomes available. You can sign on and 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
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
