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Sections 311-312 Chemical Inventory Reporting 1
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Who must report? Any facility that has a chemical or product that requires an MSDS AND The hazardous substance meets or exceeds the reportable threshold at any one time 2
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Reporting thresholds: The threshold for Extremely Hazardous Substances (EHS) is the TPQ found on EPA’s “Consolidated List of Lists” or 500 pounds, whichever is less For all other substances, the reporting threshold is 10,000 pounds 3
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Some commonly reported EHSs: o AmmoniaTPQ500 lbs o ChlorineTPQ100 lbs o FormaldehydeTPQ500 lbs o StrychnineTPQ100 lbs o Sulfuric AcidTPQ1000 lbs Remember – TPQ or 500 pounds, whichever is less! 4
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Sections 311 – 312 Exemptions Substances regulated by the FDA Solid objects, no exposure with regular use Used in routine agricultural operations Fertilizer for sale to ultimate customer Packaged for distribution and use by general public Used in research lab, hospital or medical facility under direct supervision of technically qualified individual 5
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Sections 311 – 312 Regulatory Relief Gasoline or diesel at retail gas stations only In compliance with UST regulations Less than 75,000 gallons gasoline Less than 100,000 gallons diesel fuel 6
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Section 311 MSDS Submit LIST of chemicals grouped by five hazard categories (Washington SERC prefers list!) OR Submit copies of material safety data sheets for all reportable chemicals LEPCs may ask for copies – check with your LEPC 7
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When to report? Original within 90 days of new product arriving on site or exceeding the Threshold Planning Quantity (TPQ) If the MSDS changes, submit an update within 90 days of the change This is a one time requirement 8 Section 311 MSDS
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10 Section 311 MSDS
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Section 312 Tier Two Emergency & Hazardous Chemical Inventory 11
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Section 312 Tier Two 12
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13 Section 312 Tier Two
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Section 312 Tier Two 15
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16 Section 312 Tier Two We now have a New Storage Code “S” for sulfuric acid in batteries!
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Send completed forms to SERC, LEPC, and local Fire by March 1, 2016 Original signature (all three reports) 17 Section 312 Tier Two
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Make it easy with Tier Two Online! 18 Quick & Simple Uploads previous year’s chemical data Immediately received by the SERC when you click ‘Submit’
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Tier Two Online Reporting Page 19
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Tier Two Online Chemical Page 20
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Tier Two Online Chemical Page 21
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Tier Two Online Register for Electronic reporting: www.ecy.wa.gov/epcra/saw.html OR Email: TierTwoOnline@ecy.wa.gov Be sure to mail copies to the LEPC & Fire Department 22
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Section 312 Tier Two 23 Reports are due annually on or before March 1st for the previous calendar year March 1, 2016 for reporting year 2015
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Section 313 Toxics Release Inventory (TRI) 24
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Section 313 TRI 25 Businesses must meet ALL criteria: o Certain industry category (NAICS) o Have 10 or more full-time employees o Facility uses toxic chemicals above threshold: 25,000 pounds manufactured or processed 10,000 pounds otherwise used Exception: PBT chemicals have a much lower threshold
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Questions? 26
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For more information : www.ecy.wa.gov/epcra Email: epcra@ecy.wa.gov Community Right-to-Know Unit: Iris Aguilera (360) 407-6734 Diane Fowler (TRI) (360) 407-6171 Sadie Whitener (360) 407-6729 U.S. EPA Washington Operations Office: Kathleen LeGreid (360) 753-9477 27
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