Changes to SARA Title III Coming in 2018!

by David Stegink
Sep 22, 2017
0

Changes to SARA Title III

Emergency Planning and Community Right-to-Know Act (EPCRA) Sections 311 and 312 of SARA Title III address emergency and hazardous chemical inventory reporting requirements for various facilities. Reporting these inventories assists local emergency planners and first responders by allowing them to appropriately plan for hazardous material incidents in their communities. This program has been in place since 1987, and many clients are now preparing Tier II reports annually through online portals managed by individual states.

However, recent changes are taking place within EPCRA to conform to the new OSHA Hazard Communication Standard, which incorporates the United Nations Globally Harmonization System of Classification and Labeling Chemicals (GHS). The physical and health hazard classifications used by GHS affect the reporting requirements under EPCRA Sections 311 and 312. The new classifications of physical and health hazards are more detailed and precise. Furthermore, OSHA added three new hazard classifications not covered by the GHS. Beginning in 2018, facilities reporting their chemical inventories must utilize these new physical and health hazard classifications.

Many states have developed their own software for hazardous chemical inventory reporting (e.g., Tier II reports). Other states use Tier 2 Submit, an electronic software developed by the U.S. EPA. Although OSHA adopted GHS classifications in 2012, in order to provide enough time for states and the U.S. EPA to modify their software and incorporate the new hazard classes, the final rule will not become effective until January 1, 2018. This means that by March 1, 2018, facilities are required to report the revised physical and health hazards for their hazardous chemicals present during the 2017 calendar year.

What should you do?

  • Make sure you have been provided copies of the Safety Data Sheets (SDSs) for chemicals in your inventory. SDSs incorporate the GHS classification and labeling standards and replace the familiar Material Safety Data Sheets (MSDS).
  • When completing your reporting, make sure you identify all the physical and health hazards identified on the SDS for each individual chemical. The GHS classifications have very precise definitions (See table below). Don't guess what the hazards are or assume a generic use of terms.

Envirologic is here to help! If you have questions, please contact David Stegink, Associate Vice President.

Changes to SARA Title III

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sara title iii  epcra  emergency planning and community right-to-know act  osha  safety data sheets  sds  globally harmonization system of classification and labeling chemicals  ghs


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