March 1st Plus 2: Just one more one more thing…
Section 311 update requirements…
And just one more one more thing…we covered the Section 302 updating requirements yesterday, here’s the other half, the Section 311 updating requirements.
Remember that 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).
Your 311 update is due withing 90 days if there have been changes that affect your reporting requirements
Updates for 311 MSDS reporting
The above is an FAQ that clarifies the requirements
“An update must be submitted within three months anytime there is discovery of significant new information, or
if an unreported hazardous chemical is present in a quantity exceeding the reporting thresholds”
Thus, if the facility now exceeds the 10,000 pound threshold where it didn’t before, reporting would be required. This would apply to both new chemicals and existing ones that didn’t previously exceed the 10,000 pound threshold.
“Significant changes” have a lot of flexibility in how they are defined. A change in hazards is clearly considered significant.
Above is an FAQ that clarifies “significant new information”, in the context of the Global Harmonization System GHS requirements. The FAQ also provides a broader context, however.
Check with your local regulatory authority for what your requirements are for submitting this information
You have 90 days after a change at your facility to update your Section 311 notifictions, in contrast with Section 302 for which updating is required every 60 days.
As of March 1 (or whatever date you submitted your Tier2), you were caught up to date for both Section 302 and Section 311 update requirements.
If you just run this on the same 60 day calendar on which you are updating your Section 302 information, you will always be in compliance.
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 311 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 #Secton311
