Several years ago, the Occupational Safety and Health Administration (OSHA) revised their Hazard Communication Standards (HCS) in response to the United Nations Globally Harmonization System.
The changes to OSHA’s HCS affect specific Environmental Protection Agency (EPA) reporting requirements. Accordingly, the EPA recently issued revisions to the hazard categories in the regulations under 40 CFR Part 370 for reporting under Sections 311 (Tier I) and 312 (Tier II) of the Emergency Planning and Community Right-to-Know Act (EPCRA).
Previously, reporting hazardous chemicals under Sections 311 and 312 required each chemical to be placed into the following five hazard categories: Fire, Sudden Release of Pressure, Reactive, Immediate (Acute), Delayed (Chronic).
With the recent revisions, the EPA is adopting more than 20 hazard categories from the revised HCS for reporting under Sections 311 and 312. The list of hazard categories are in the following chart:
When Do the EPCRA Changes Go into Effect?
The final rule will be effective on January 1, 2018. This means that by March 1, 2018, facilities reporting under Sections 311 and 312 are required to report the revised physical and health hazards for the hazardous chemicals present during the 2017 calendar year.
Michigan recently announced an upcoming revision to their web-based reporting system, and we expect similar actions in other state-lead jurisdictions.
Will I have to report more chemicals based on this change?
The number of reported chemicals will not be affected by this revision, as the threshold values have not been changed. The revision only updates the hazard categories.
If you have questions or require assistance, please feel free to contact me at 248-932-0228, ext 103.