III. WHAT IS REQUIRED FOR HAZARDOUS MATERIALS STORAGE REPORTING?
(SECTIONS 311 - 312)
If your facility is covered by the state or federal OSHA Hazard Communication Standard and you store OSHA-regulated substances above the EPA-established thresholds, you are likely covered by these sections. The reporting threshold for any substance requiring a material safety data sheet (MSDS) is 10,000 pounds. For Extremely Hazardous Substances, the reporting threshold is 500 pounds or the TPQ, whichever is lower. If you store hazardous materials in excess of these thresholds at any time during the year, you must file under Sections 311 and 312.
What Must I File and with Whom?
To fulfill the requirements of Section 311, you must submit a copy of the material safety data sheet for each reportable hazardous substance (see the thresholds described above) or a list of these hazardous substances grouped into the five EPA hazard categories -- acute health effects, chronic health effects, fire hazard, sudden release of pressure, and reactivity.
The MSDSs or catergorized list of substances must be submitted to the state Commission, the LEPC and your local fire department. Contact your county board of commissioners or the state SARA Title III Office for the local committee in your area. This submission is required only once unless changes are made in the hazardous materials your facility stores.
Are There Any Annual Reporting Requirements?
Yes. Facility owner/operators must submit hazardous materials inventory information using either a Emergency and Hazardous Chemical Inventory Tier One or Tier Two reporting form.
The Tier One form includes aggregate information about hazardous substances and their general locations grouped by major hazard category. Tier Two information is chemical-specific and location-specific. Facilities may submit either of these forms to comply with Section 312. However, because the Tier Two information is chemical-specific it is generally more useful to emergency responders. The state Commission recommends that facilities submit the Tier Two form; and in some cases, LEPCs require the Tier Two.
Copies of the forms must be submitted to the state Commission, your LEPC and your local fire department by March 1 of each year. The public may obtain hazardous substances inventory information for a specific facility through their LEPC or the state Commission.
NOTE: Most employers in Michigan are also required to follow the requirements of the Michigan Worker Right-to-Know Law. Contact your MIchigan OSHA office for more information.
Are There Exemptions for Certain Activities or Substances?
Yes. For example, hazardous substances used under the supervision of a technically qualified individual in a research lab, hospital or medical facility may be exempt. Materials used by state or municipally-owned and operated facilities are exempted from reporting. Chemicals that are used in routine agricultural operations and are stored by the end-user are exempted as well.
Other substances which do not need to be reported include hazardous wastes, materials packaged for household use, food and drugs. For specific exemptions, consult the appropriate federal regulations.
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