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In our newest installment of Ask the Professional, dropped at you by the workforce of business consultants at EHS Hero®, we have a look at a current query from a subscriber asking concerning the laws that require notifying prospects of reportable chemical compounds. See what the consultants needed to say.
Q: What regulation requires you to inform your buyer that you’re sending them a chemical with an EPCRA 313 reportable chemical?
Such notifications are required underneath 40 CFR 372.45, titled Notification About Poisonous Chemical compounds. Below this regulation, notification should be made by any one who owns or operates a facility that:
- Is in SIC codes 20 by means of 39 or a NAICS code that corresponds to SIC codes 20 by means of 39;
- Manufactures, imports, or processes a poisonous chemical (i.e., a Toxics Launch Stock (TRI) chemical), and
- Sells or in any other case distributes a combination or commerce title product containing the TRI chemical, to:
- A facility topic to TRI reporting underneath EPCRA 313, as described in 40 CFR 372.22; or
- An individual who in flip might promote or in any other case distributes such combination or commerce title product to a facility described in 40 CFR 372.22(b).
The notification should be offered to every particular person to whom the combination or commerce title product is offered or in any other case distributed. The notification should be in writing and embody the next info:
- A press release that the combination or commerce title product comprises a poisonous chemical or chemical compounds topic to TRI reporting underneath EPCRA 313 and 40 CFR 372;
- The title of every poisonous chemical, and the related Chemical Abstracts Service (CAS) registry variety of every chemical, if relevant; and
- The % by weight of every poisonous chemical within the combination or commerce title product.
The notification should be made with the primary cargo of every calendar yr, at a minimal. It is not uncommon that this notification is included into Part 15 of the Security Information Sheet (SDS) for the chemical or combination. Nevertheless, the notification is usually a letter. If you’re required to arrange and submit an SDS, the letter should be connected to the SDS. As well as, it’s best to make it clear to your prospects that they have to embody the TRI provider notification if they supply the SDS to any of their prospects.
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