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The Big Report on Your Annual Hazardous Chemical Inventory Reporting

There should never be anything left to chance regarding the usage and care of hazardous chemicals in your business. Also as important is the annual report of their inventory to OSHA.

A list of things to know to make your business less hazardous… 

March 1 is the annual deadline for submitting your report. It’s not something to be done at the last minute.  Companies that need to report are those with a hazardous chemical that falls under the OSHA hazard communication rule.

So, are you presently harboring an OSHA-hazardous chemical? While there’s no official listing, OSHA defines a hazardous chemical as “one that poses a physical hazard or health hazard.” They provide a 20-count criteria for determining if something IS a hazard along with hazard communication resources on their web site.

Specific materials that require reporting are any onsite chemicals at or above their threshold quantities—10,000 pounds or more present at one time—during the previous year. For extremely hazardous substances (EHS), the reporting threshold is the lower of either 500 pounds or the threshold planning quantity. (Gasoline and diesel fuels fall under separate reporting thresholds.)

To determine whether you have met the reporting threshold for EHS, you need to aggregate the amount of the EHS in mixtures with other EHS quantities. (The threshold for gasoline and diesel fuel applies to the aggregate of all blends).

Responding to local authorities’ request for a chemical inventory report is absolute: even if you have not exceeded any thresholds, they can request and receive information on any hazardous chemical in any quantity.

Your annual report must also be submitted to your emergency planning committees on the local and state level, as well as to your local fire department. The EPA maintains a searchable online database of LEPCs (local level) and a comprehensive list of SERCs (state level).

 Following Good Form(s)….

As may be expected, filing the proper forms PROPERLY is critical to staying compliant for housing hazardous chemicals. As a rule, you may submit either a Tier I form for your ENTIRE inventory, or Tier II forms for EACH chemical. The EPA provides these forms at their site.

A Tier I form must include general information about all the chemicals at your facility, including the maximum amounts present, the potential physical and health hazards posed by each, average daily amounts present, their general locations at the facility, number of days on site, and other information as deemed necessary.

A Tier II report must include specific information per each, including:

  • CAS number
  • chemical /common name
  • whether pure or a mixture
  • physical state
  • EHS or non-EHS
  • hazard category

Be prepared to provide both.

Submit your report electronically for Tier II forms only if accepted by your state. The EPA provides software for this as well as directions on their Tier II Chemical Inventory Reports page.

As long as you are in good stature in Hazardous Chemical Care, Good Reports will also help keep you in Good standing.

Need someone to make sense of this for your business?  We deal with these issues every day.  Contact Us (859-689-9222) to get more information about how we can help your business be less hazardous.

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