March 1st Plus 1: Just one more thing…
Don’t forget your Section 302 and Section 311 update requirements…
Just one more thing….if you remember Colombo, the TV show. For those of you who missed it, he would turn around and ask the person who turned out to be the perpetrator “just one more thing” about a gazillion times in each episode.
So here’s your “just one more thing” (it’s two actually, but we’ll do the second one tomorrow).
Your Section 302 update is due within 60 days of Tier2 report submission and your 311 update is due withing 90 days if there have been changes that affect your reporting requirements
Your Tier2 report counted as your both your Section 302 notification (required to be updated with changes within 60 days of the change occurring) and your Section 311 update (required within 90 days of the change).
In my experience, these are the least complied with SARA reporting requirements.
We’ll address Section 302 today and Section 311 tomorrow.
EPCRA Section 302 requires a one-time notification if you have chemicals on-site that are/contain Extremely Hazardous Substances (EHS’s) that exceed their Threshold Planning TPQ.
Unlike Tier2 where you report if the aggregate EHS amount on-site at any time exceeds the TPQ or 500 pounds, whichever is lower, this requirement does NOT default to the lower 500 pound level, it is the actual TPQ.
Here’s an FAQ that seems unrelated but gives you a pretty good summary of Section 302 requirements in terms of determining whether you need to report.
If you didn’t exceed the TPQ yet for a chemical, you would need to report it. If you aready reported for that EHS but this is a new product/Tradename that contains that EHS, you might need to report it.
Check with your local regulatory authority for what your requirements are for submitting this information
You have 60 days after a change at your facility to update your Section 302 notifictions.
As of March 1 (or whatever date you submitted your Tier2), you were caught up to date on this one.
I would suggest putting a reminder on your calendar for about 53 days from your Tier2 submittal date to revisit changes to your Safety Data Sheets to identify materials that may have exceeded TPQ thresholds that hadn’t exceeded the threshold/been reported before, or for new products/tradenmanes that contain EHS’s that you have already reported .
That gives you a week to get things in order.
In the meantime, figure out what processes you are going to use to get the information you need for this update reporting. And implement them.
Google calendar calculated 60 days from March 1 to be Saturday April 30, so Friday April 22 or Monday April 25th would be good days for your reminder to pop up (or earlier if you submitted earlier than March 1 or think you will need more time to obtain the information you need).
Have it be a repeating task every 60 days from there.
Tomorrow we’ll revisit Section 311 updates, which are updates for Hazardous Substances (have a Safety Data Sheet, reportable at 10,000 pounds on-site at any given time.
Call to the community:
What tools do you have in place to track the changes that have occurred for which you need to update Section 302 requirements?
Now we’ll just call these SARA updates…here’s to Continuous Improvement of your processes!
#SARA302 #SARATierII #SARATier2 #EPCRA #EGLE #ThresholdDeterminations #ExtremelyHazardousSubstances #EHS #ThresholdPlanningQuanitity #TPQ #EPAFAQ #CERCLAFAQ #SARAFAQ #EHSThresholdDeterminations #Secton302
