isat 422: environmental management disasters and right to know n unlike osha, focus is on...

ISAT 422: Environmental

Management

Disasters and Right to Know

Unlike OSHA, focus is on non-employees– Neighbors in community– Emergency responders – Public at large


Management

TSCA – Toxic Substances Control Act

1976 (amended 1986 for asbestos, 1988 for radon, 1992 for lead)

Regulates manufacture &c of chemicals Gather basic information on chemical risks Hazard warning labels up to ban Weigh risks vs. benefits


Management

TSCA (cont’d)

Excludes– Pesticides (FIFRA)– Tobacco (BATF)– Nuclear (NRC)– Food/Drugs (FDA)– Guns (BATF)

Manufacturers vs. Processors Procedure on pg. 503 Recordkeeping


Management

EPCRA/SARA Title III

Emergency Planning and Community Right-to-know Act

1986 Stand-alone bill added to SARA (Superfund

Amendments and Reauthorization Act, which was currently in front of Congress)

Triggered by Bhopal and Institute, West Virginia


Management

311: Emergency coordinator

Applies to companies in 20 industries (designated by Standard Industrial Classification, SIC, codes)

Requires designation (in writing) of an Emergency Coordinator to cooperate with Local Emergency Planning Committee (LEPC).


Management

311 (cont’d)

Requires sending of list (or usually MSDSs) of 312 materials to the LEPC, fire department, and State Emergency Response Commission (SERC)


Management

312: Tier I/II Reporting

Annual reporting (March 1) to LEPC, fire dept, and SERC of chemical products stored on-site in greater than threshold quantities


Management

312 (cont’d)

Reportable quantity means, for any CERCLA hazardous substance, the amount that, if released to the environment within a 24-hour period, must be reported to the National Response Center

Reportable quantities are established in Table 302.4 of 40 CFR part 302, for such substance. The default reportable quantity is one pound.


Management

312 (cont’d)

Threshold planning quantity means, for any extremely hazardous substance listed in appendices A and B, the quantity listed in the column “threshold planning quantity” for that substance.

If total storage is in excess of TPQ, then 40CFR355 (Emergency Planning and Notification) applies.


Management

312 (cont’d)

Uses Tier I/Tier II form (or local variant)– Tier I presents info on aggregated chemical

groups, while Tier II is on individual substances

– Tier II may be submitted in lieu of Tier I– Tier I required annually (March 1), & Tier II

can be requested by LEPC &c, and then must be provided within 30 days (so usually just submit it to begin with)


Management

313: Form R, Toxics Release Inventory

Toxic Chemical Release Inventory Report (via “Form R”)

Annually on July 1 Reports releases of “toxic chemicals”

reasonably expected to cause adverse human health effects or significant adverse effects on the environment

Complicated applicability criteria


Management

CAA 1990: Risk Management Plan

Section 112 of the CAA of 1990 addresses accidental release of toxics into the atmosphere

Implementation by EPA (see 40 CFR Part 68) Provides a “general duty” notion that facilities

must – Identify hazards from releases– Design and maintain a safe facility, and– Minimize consequences of release


Management

RMP

Applies to certain listed chemicals, based on threshold quantities specific to each– E.g. chlorine is 2500 lbs, arsine is 1000 lbs

Stationary sources (but this includes parked transportation containers)


Management

Major Provisions

Provide for accidental release detection and prevention– 112(r)(7)(B)(i)

Develop a Risk Management Plan providing government and the public with assessments and planned actions– 112(r)(7)(B)(ii)

Submit and audit the RMP– 112(r)(7)(B)(iii)


Management

CSB Disc one, #4: Emergency in Apex

isat 422: environmental management disasters and right to know n unlike osha, focus is on...

Documents