54 days: Obtaining data for materials received on-site last year.
SARA 312 Tier 2: 53 Days until deadline & counting down
How do you know what materials were received on-site last year?
“We processed 165,000 transactions from one system and 99,000 from another. And that was only the transactions tagged as having a transaction that had a Safety Data Sheet associated with it” Automotive Client
For a typical manufacturing plant, our experience was that about 10% of receipt transactions from their Enterprise Resource Planning ERP systems were for materials associated with a Safety Data Sheet SDS
A typical facility has multiple ways that chemicals are purchased and received onto the property, which puts them “on-site” for purposes of your Threshold Determinations.
Different ways chemicals might be received on-site
These might include:
Direct Materials: Materials that become part of the end product. Body paint, brake fluid, and gasoline in automotive assembly plants, for example. There are typically not a lot of these but they tend to be large quantities
Indirect Materials: Everything else purchased by the facility to support the activities used to create the items that were received as Direct materials. Usually a larger number of individual items but smaller quantities of each
It used to be quite common for these different types of materials to be maintained in 2 different purchasing systems. With the advent of SAP and similar products, the 2 types of information might be in a single source system.
With respect to threshold determinations for Tier 2, there is no difference in how the materials are managed.
Contractor Materials: Materials that contractors bring on site could expose emergency responders, and so need to be part of your facility Tier II/2 report. These might include cooling tower chemicals, refrigerants if you outsource your HVAC, remediation chemicals if you are treating groundwater on-site, you get the picture.
If you outsource your entire Maintenance function, you will need to coordinate with the company performing that function for you.
Since the purpose of this report is to protect emergency responders, the fact that they could be exposed to contractor chemicals on your site means they need to be included in your facility’s report.
Note that the Contractor’s purchases/.inventory of Extremely Hazardous Substances EHSs will need to be added to yours before conducting EHS threshold determinations.
Overnighted/Expedited receipts: One client received and barcoded everything either through their “dock to stock” supplier, who sent an electronic record of what materials and amounts the barcodes on their packages represented, or through their main receiving dock.
It turned out that expedited (FedEx, UPS Overnight, etc.) came into the main visitor desk and completely bypassed the labeling process. We discovered this doing physical inventories when we came across unlabeled materials.
Corporate Credit Card purchases: It’s not unusual for someone to go down to the Big Box store and make a purchase. These purchases are frequently the source of missing Safety Data Sheets in your system and are sometimes overlooked for Tier II/2 and Toxics Release Inventory TRI SARA 313 reporting. A spreadsheet or other electronic download might be available for these. Transactions will need to be filtered line by line to see if they apply, and some investigative work is likely to be needed.
Petty Cash purchases: This one is even worse than Corporate Credit Card purchases. For these transactions, you will need to review actual receipts, in all likelihood.
Why is this a rate-limiting step?
This is actually an activity you would have ideally done last fall (or last January so you had a year of transactions ready to go).
If you’re not already doing this, it will probably take time and some interactions for you to find out what your purchasing systems are, reach out to the appropriate people, agree on a download format, and resolve any glitches with the files you receive
What are some benefits?
If you can get the supplier to add unique barcode (or other protocol) identification labels to the containers they send in, and then send you the electronic file that says what each record represents, you can reduce inventory in the future by 80% plus.
An aerospace facility was able to get their suppliers to do this surprisingly easily. The supplier was already putting on a custom label, they just had to add 1 field to it.
Looking at the transactions and doing some selective sorting (lowest amounts and highest and vice versa) you can look for transactions that look out of place and can obtain adjustments accordingly (or find out why there was such a big difference)
Once you’ve set up the protocol you can reuse it from year to year
Some systems may be able to provide starting/ending inventories in addition to transactions (you would want to verify). Many frequently do a rolling real-time physical inventory which you can tap into going forward.
More on this topic in later posts…
Reaching out to the community:
Are there other ways materials are received at your site besides the ones mentioned? How do you obtain the amounts of Tier 2 materials received on-site? What has your experience been? What glitches have you encountered and how did you overcome them?
53 days and counting down…More tomorrow, here’s to March 2nd!
#SARA312 #Tier2 #EPCRA #RightToKnow #March1Deadline #purchasinginterface
