TIER II REVISIONS CLARIFIED FISHBECK THOMPSON CARR HUBER
TIER II REVISIONS CLARIFIED FISHBECK, THOMPSON, CARR & HUBER engineers | scientists | architects | constructors
10 FTCH FACTS Est. Lansing, Michigan in 1956 Architecture/ Engineering Infrastructure 400 (A whole lot of brain power!) EMPLOYEE OWNED OFFICES Grand Rapids, Michigan Kalamazoo, Michigan Lansing, Michigan Macomb, Michigan Detroit, Michigan Novi, Michigan Traverse City, Michigan Cincinnati, Ohio Columbus, Ohio Lafayette, Indiana Environmental Construction 207 SHAREHOLDERS 100 AWARD WINNING PROJECTS
• Tier II ¡ ¡ ¡ Implementation Resources Enforcement Agenda
IMPLEMENTATION
Understand the Hazard Categories
• If SDS meets GHS requirements, then should be easy data transcription; no interpretation required • SDS are not always updated, although required by law back in 2015 Get Current Versions of Safety Data Sheets (SDS’)
“Good” Example of SDS
“Bad” Example of old MSDS
RESOURCES
EPA EPCRA Website
MDEQ EPCRA Website
• EPA List of Lists: https: //www. epa. gov/sites/production/files/201503/documents/list_of_lists. pdf • OSHA GSH Guide: https: //www. osha. gov/dsg/hazcom/ghsguideoct 05. pdf • Free SDS database: www. chemicalsafety. com/sdssearch • Chemical Suppliers • Consultants Other
ENFORCEMENT
• $37, 500 $54, 789 (per day, per violation) EPCRA Increase in Daily Max Civil Penalty
• Considering lead acid batteries as exempt articles like TRI • Forgetting about EHS’ with lower thresholds such as ammonia and sulfuric acid • Forgetting about diesel ASTs (not at retail gas stations) • Remembering that anything with a SDS (and physical and/or health hazard) needs to be considered Common Tier II Mistakes
Not Reporting to LEPC
• Light Manufacturing/Warehouse Client in Grand Rapids Area Lead Acid Battery EPA Notice of Violation & Fine
• Tuna Processor in American Samoa Multi-Program EPA Settlement, with EPCRA Self-Disclosures
www. ftch. com
THANK YOU FISHBECK, THOMPSON, CARR & HUBER engineers | scientists | architects | constructors
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