Category: Ask the Expert

SDS Requirements

Q. Can you provide some guidance on how to satisfy the requirements of the Safety Data Sheet (SDS) information without revealing the names or Chemical Abstracts Service (CAS) numbers of the chemicals we use in our mixtures?

Spill Reporting

Q. Would flavorings that contain small amounts of oil (for example, almond and hazelnut oil) count towards an inventory to determine Spill Prevention, Control, and Countermeasure (SPCC) applicability if they are stored in 55 gallon drums or greater?

TRI Reporting

Q. An EHS chemical, Sulfuric Acid, exceeds 500 pounds. Therefore aggregation of Sulfuric Acid containing compounds is required in TRI reporting. In that aggregation, are lab chemicals included or exempted?

Flammable Substance Threshold

Q. Would the risk management plan (RMP) flammable substance exemption include warehouses? We will store cans of foam containing isobutane. Will the RMP regulations apply?

Identifying EHSs

Q. How do I identify extremely hazardous substances (EHSs) and hazardous substances on EPA’s List of Lists and SDSs?

Shipping Aerosols

What type of protective cap must be placed on aerosols if you don’t remove the nozzle? Is this the case if they are shipped in a 55 gallon drum? Or only if shipped loosely?

Turpentine Storage

Q. Is turpentine covered under Spill Prevention, Control, and Countermeasure (SPCC) and what are the spill containment requirements for AST of turpentine?

SPCC: PE Certified Revision Required

Q. Does replacing a 1000 gallon UST with an 8000 gallon UST in the same location require a PE-certified revision to the SPCC Plan if nothing else has changed at the site?