Ohio SARA 312 Tier 2 Reporting Update


Effective January 15, 2018, Ohio EPA has adopted amendments to OAC rule 3750-30-25, which changes the definition of “hazardous chemicals.”
 
Facilities in Ohio that store or use 10,000 pounds or more of a “hazardous chemical” or more than the “threshold quantity” of an “extremely hazardous substance” must submit a SARA Tier 2 report by March 1st of each year. The “threshold quantity” for “extremely hazardous substances” varies between 1 and 500 pounds depending on how hazardous the chemical is. The list of “extremely hazardous substances” and their associated “threshold quantities” is available at http://epa.ohio.gov/Portals/27/serc/SERC_EHS_List.pdf.
 
The SARA Tier 2 report requires facilities to identify the quantity and location of each “hazardous chemical” stored onsite. Details on completing the SARA Tier 2 report can be found at http://epa.ohio.gov/Portals/27/serc/SERC_Manual.pdf.
 
The new definition of hazardous chemicals is separated into two categories:
 
• A “health hazard” is a chemical which poses one of the following hazardous effects: carcinogenicity, acute toxicity, aspiration hazard, reproductive toxicity, germ cell mutagenicity, skin corrosion or irritation, respiratory or skin sensitization, serious eye damage or eye irritation, specific target organ toxicity, simple asphyxiant, and hazard not otherwise classified (HNOC).
 
• A “physical hazard” is a chemical which poses one of the following hazardous effects: flammable, gas under pressure, explosive, self-heating, pyrophoric liquid or solid, pyrophoric gas, oxidizer, organic peroxide, self-reactive, in contact with water emits flammable gas, combustible dust, corrosive to metal, and hazard not otherwise classified (HNOC).
 
The previous version of the rule separated hazardous chemicals into the following categories:
 
• Immediate (acute) health hazard
• Delayed (chronic) health hazard
• Fire hazard
• Sudden release of pressure
• Reactive
 
The amendments to this rule incorporate recent changes to USEPA’s hazardous chemical reporting regulations to conform to revisions in OSHA’s Hazard Communication Standard due to OSHA’s adoption of the Global Harmonizing System (GHS) classification and labeling of chemicals.
 
All future SARA Tier 2 reports must specifically identify the type of “health hazard” or “physical hazard.” For example, acute toxicity if the “hazardous chemical” is a “health hazard” or explosive if the “hazardous chemical” is a “physical hazard.” Typically, this information can be obtained from the Safety Data Sheet.
 
If you have any questions, contact Ron Hansen at 614-794-3570 Ext. 21.

by Ron Hansen and Derek Kirkbride