19 days: Saturday edition of FAQ Friday

Are you getting close to being finished yet?

20 days: A new round of FAQ Friday

A few more selected FAQs,

21 days: Hazards for EHS containing mixtures where the EHS is reportable

(First a story from my early days in the plant that’s reflected in this cartoon)

With respect to the hazards associated with Extremely Hazardous Substances EHS’s in mixtures, it’s a “both and” situation:

• Figure out the hazards for the EHS by itself (get a Safety Data Sheet SDS for it if you don’t already have one

• Compare that with the hazards of the mixture. If the EHS is at sufficiently low concentration, the hazard of the pure EHS may not be exhibited

• If you dont think the SDS has sufficiently detailed information, try to get better information

• If all else fails, use your judgment

22 days: Hazards, more about

Finding the hazards for materials Reportable by Amount (Hazardous Substances with more than 10,000 pounds maximum on site at any given time during the year)(only, no Extremely Hazardous Substances EHSs in them) should be straightforward, (simply) check Section 2 of the Safety Data Sheet SDS Hazard Identification

(Any time someone says “all you have to do is” you know you’re in trouble)

We’ll review the EPA guidance about what to do if you can’t get good information or if there are contradictions (from yesterday’s pdf)

Tomorrow we’ll look at work-arounds and after that we’ll start looking at hazards for Extremely Hazardous Substances EHSs

23 days: Time to start looking at Hazards for your reportable chemicals.

We’ll come back to fine tuning your thresholds, but since finding good Hazard information may take a little time I wanted to kick that off now.

Post includes link to an EPA document with some background, the “Crosswalk” from the old to the new, and a really good Q and A at the end about how to deal with challenging situations

24 days: Find out when your authorized signer is available and get on their calendar

The authorized signer needs to be an official of the company and have the authority to budget resources for implementation and compliance of Tier2 requirements.

Also find out what needs to be done to get that person authorized to sign both electronically and physically if it’s a new person. There may be a lag between when you submit the request to authorize the person as a signer and when they can actually log into the software to certify.

And remember there are no extensions to the deadlline for Tier2 submission

Be sure to leave time for review of your supporting documenttion.

25 days: Even More FAQ Friday

A few more selected FAQs, these ones include: - Did you know you can deviate from the standard Container Types (I didn’t)?; Acid Mixtures, Hazardous Chemicals in Vehicles, and EHS Aggregation

26 days: More FAQ Friday

A few more selected FAQs, these ones around extension (none available but the FAQ tells you why), what your obligations are if March 1 falls on a weekend, the official FAQ on researching bad CAS Numbers, and whether Contractor materials need to be included in the Tier2 report of a facility at which they are doing work. Oh, and an obscure FAQ about reporting jurisdiction for release from an aircraft (not Tier2 related, from before I figured out how to filter the FAQs from 303 to 146)

27 days: FAQ Friday

A few selected FAQs about where to get help, and down a rabbit hole around EPA EPCRA training

28 days: Exemptions

Here are the other 5 FAQs around exemptions. The first 2 are a little obscure (oil field boosters and ag turf chemicals), but the last 3 are about batteries, probably of interest to most

29 days: Exemptions

You don’t even need to bother with this for anything that didn’t exceed threshold determinations in the previous step

And you might not want to bother with them for any materials that exceeded thresholds where exemptions won’t make a difference in whether the material is reportable or not.

This post will point to the main EPA FAQ about this topic and to some related FAQ questions.

Today we’ll go through the first 4 FAQ’s

30 days: Threshold determinations, finally!

This is actually one of the easier steps of the Tier2 process.

• Compare the Max On Site (total amount, not by CAS number) to 10,000 pounds (or your regulatory equivalent)

• Match to Extremely Hazardous Substance EHS CAS Numbers.

• For CAS Numbers that match an EHS CAS Number, compare the CAS Total Amount to the Lower Threshold Planning Quantity TPQ or 500 pounds, whichever is lower (we’ll figure out what can be compared to the Upper TPQ in another post)

• For anything where the CAS total exceeds that amount, all SDS’s containing that CAS Number (subject to excemptions and other special cases we’ll cover in later posts) need to be included on the Tier2 report

31 days: Verifying you have the correct list of Extremely Hazardous Substances EHSs

For this, the EPA Consolidated List of Lists is the definitive guide. For RY 2021, the version was published Sept 2021.

If you’re lucky, you have a regulatory update service that makes this automatic.

If you need to do the manipulation yourself, we’ll talk about a few considerations

32 days: SDS Constituents and ambiguous CAS Numbers: Phenol example

This example shows multiple different valid CAS Numbers, all with a Constituent Synonym of Phenol (and one Proprietary entry for the CAS Number) and takes you through resolving them.

33 days: SDS Constituents cleanup: Sulfuric acid example

We’ll see Sulfuric acid in its usual expected CAS Number for lead acid batteries

I’ll also suggest other places you may have it on-site (remember that Why A Full Inventory post earlier in the season?)

Then we’ll look at an example for Fuming Sulfuric Acid where you’ll get to look at the EPA LIst of Lists in detail around this topic.

34 days: SDS Constituents and CAS Numbers: Connecting the dots

Now you’ll look at Constituents to

• find ones that could be turned into a “proper” CAS Number and make those changes,

• check for incorrect CAS Numbers (CAS Numbers that don’t match the check digit algorithm) and fix those where you can, and

• annotate CAS Number/Constituent Synonym combinations s that you are accepting as OK with respect to your reporting requirements and which you won’t be conducting further follow up on in the future.

A couple of examples in the next 2 days

35 days: Constituents Greater than >, Less than <, Range, and Balance: Safety Data Sheet Cleanup before Threshold Determinations, part 2

Greater than use 100 or calculate a more accurate value

Less than < drop the less than sight and use that value

Range we use the upper range for the first threshold determinations

Balance either use 100 or calculate known percentages and subtract those from 100

36 days: Safety Data Sheet Cleanup before Threshold Determinations, part 1

Create a report descending by the amount on-site; associate the constituent percentages, enter constituents for SDS’s that don’t have any; resolve any constituents cross referenced instead of entered; check for non-valid duplicates; check for missing constituents “hidden” by a consolidated CAS number; and reolve sum of constituent percents zero or less than 100.

Is that enough for 1 day? more tomorrow!

37 days: Review of on-site amounts before SDS constituent cleanup before threshold determinations

Steps to actually set up your conversions, and steps to review the resulting data to see if it matches the reality that you know to be true about facility operations

38 days: Converting from Purchasing Units of Measure UOM Part 2

Now you need to convert the more challenging Units of Measure for receiving. There are 2 cases (bad pun)

• Units of measure that consist of multiples of standard units of measure, for example, a Case of 12-18 ounce cans. Simple multiplication against an ending UOM that is in a conversion table somewhere

• Part-specific Units of Measure: Each, Piece, Can, Drum, Roll. The Unit of Measure UOM in this case gives you no indication of the conversion factor