56 days: Why not just use last year’s info?
SARA 312 Tier II/2 55 Days left, counting down
"Why conduct a physical inventory and obtain purchases instead of just using what I know from last year?"
“When it’s time for action it’s too late to prepare” Ray Hunt, Horseman
From my experience, the steps that take the most time for your SARA 312 Tier II/2 report are:
· Conducting your physical inventory.
· Obtaining data for the materials received on-site last year.
We’ll do a more detailed blog post about each of these in the next couple of days, but first let’t talk about the Why.
(Below is an exerpt of the high-level Tier 2 flowchart so you can see the steps).
Exerpt of early steps of high-level SARA 312 Tier 2 process steps
Why would I want to do a Physical Inventory and obtain Materials Received as part of Obtain Data for Threshold Determinations?
If this isn’t the first year you’ve done the Tier2, you have last year’s report. So why not use that as your starting point?
· You probably also need to do a Toxics Release Inventory TRI report due July 1 (if not, you need to document why you didn’t need to. Different chemicals, different criteria. )
· You may have other environmental or safety reports required also. For example, once a monthly feed was set up from the various Purchasing sources, reports such as Hazardous Air Pollutants HAPs became much easier, faster, and more accurate to prepare for a Title V facility
When you determine the maximum amount of every chemical you have on-site, and how much came on-site in the previous year, you can use this single effort for the starting point for both reports. And a plus, they will be consistent.
· You may think you know everything about what chemicals are on-site and where. You may be surprised by what you find!
Remember, for Extremely Hazardous Substances EHS, once a CAS# (Chemical Abstract Services number, the unique identifier for chemicals in the US) is Tier2 reportable you have to report ALL materials that contain that CAS#.
After you obtain all your inventory and purchases and conduct your Safety Data Sheet SDS cleanup, you may be surprised
· Since you’ll be starting with the maximums and conducting thresholds on everything, you have a very defensible case for materials not reported
And anything below the thresholds for this “worst case” you can ignore until next year or the next report.
· You may get surveys from time to time asking “do you have this on-site?
If you do, instead of having to initiate a new facility-wide search, you can check your inventory and purchases since then.
My favorite example of this is when Corporate sent out a survey “do you have any of these? They become shock sensitive after 2 years.”
Checked the inventory, sure enough, there were containers in the Chem Lab that had been in the initial inventory 8 years ago and were still there. The HazMat contractors came in and safely took the chemicals away.
More tomorrow, here’s to March 2nd!
#SARA312 #Tier2 #EPCRA #RightToKnow #March1Deadline #visio
