Regulatory Drivers for the Development of the Chemical Management System
Memorandum of Agreement
between EPA and DOE, March 23 1998
Facility-wide Process Evaluation (Phase 2): BNL will conduct
an evaluation of all experimental and industrial-type operations to
identify all the waste streams generated at the facility and determine
the compliance status of each waste stream and ensure that all waste
stream generators practice proper waste management and handling. BNL
will also identify pollution prevention, waste minimization and control
opportunities. The facility will utilize the appropriate techniques and
track the benefits.
Environmental Management Systems Audit Agreement (Phase 3):
DOE and BNL will develop a five-year annual audit program to evaluate
the facility's progress in implementing an effective Environmental
Management System designed to assure full compliance with regulatory
requirements and provide for continuous improvement in environmental
stewardship.
See SBMS Subject Area
"Process Assessment" for more information on how to conduct an
assessment on an industrial process or on experimental research.
OSHA 29 CFR 1910.1200 "Hazard Communication Regulation"
The Hazard Communication Regulation ensures that the hazards of all chemicals produced or
imported are evaluated, and that information concerning their hazards are transmitted to
employers and employees. This transmittal of information is accomplished by means of
a comprehensive hazard communication program, which include container labeling and
other forms of warnings, material safety data sheets and employee training.
BNL
SBMS Subject Area: Chemicals, Working With
This subject area serves as an essential component of the BNL work
planning and control requirements for work involving chemicals. It is BNL's
Hazard Communications Program. These
chemical safety requirements address training, selection, use and handling,
storing, transporting (on-site and off-site), and disposal in a manner that
meets Laboratory expectations.
OSHA 29 CFR 1910.1020 "Access to Employee Exposure and Medical Records"
- Material Safety Data Sheets...or a chemical inventory or any other record
which reveals where and when used and the identity (e.g., chemical, common,
or trade name) of a toxic substance or harmful physical agent.
- retained for at least 30 years
OSHA 29 CFR 1910.1450 "Occupational Exposure to Hazardous Chemicals in
the Laboratory"
- The employer shall provide employees with information and training to
ensure that they are apprised of the hazards of chemicals present in their
work area.
- Employers shall maintain any Material Safety Data Sheets...of hazardous
chemicals, and ensure that they are readily accessible to laboratory
employees.
"Emergency Planning and Community Right-to-Know Act (EPCRA)"
- The Emergency Planning and Community Right-to-Know Act (EPCRA), also
known as SARA Title III, was enacted in October 1986. This law provides
an infrastructure at the state and local levels to plan for chemical
emergencies. Facilities that store, use, or release certain chemicals,
may be subject to various reporting requirements. Reported information
is then made publicly available so that interested parties may become
informed about potentially dangerous chemicals in their community. EPCRA
requirements include:
Emergency planning
notification (EPCRA §302)
Emergency release
notification (EPCRA §304)
Hazardous chemical inventory reporting (EPCRA §§311/312)
Toxics Release Inventory (TRI) reporting (EPCRA §313)
EPCRA Chemicals and Reporting Thresholds
| |
Section 302 - Emergency Planning |
Section 304 Emergency Notification |
Section 311/312 Right-to-Know |
Section 313 Toxic Release Inventory |
| Chemicals Covered |
356 extremely hazardous substances |
>1,000 substances |
500,000 products |
650 toxic chemicals and categories |
| Thresholds |
Threshold Planning Quantity 1 - 10,000 pounds on
site at any one time |
Reportable quantity, 1-5,000 pounds, released in
a 24-hour period |
TPQ or 500 pounds for Section 302 chemicals;
10,000 pounds on site at any one time for other chemicals |
25,000 pounds per year manufactured or processed;
10,000 pounds a year used; certain persistent bioaccumulative toxics
have lower thresholds |
SARA Title III: The Emergency Planning and Community Right-to-Know
Act FactSheet
Title III Consolidated List of Lists - 2000 Version
DOE O 151.1 Chg 2 "Comprehensive Emergency Management System"
4. Requirements
a. General
Emergency planning shall include identification of hazards...
DOE G 151.1-1 "Hazards Surveys and Hazard Assessments, Emergency
Management Guide Volume II" Series 100 (TEXT) (PDF)
The purpose of this volume is to assist...in complying with the DOE O
151.1 requirement that Hazards Surveys and facility-specific Hazards
Assessments be prepared, maintained, and used for emergency planning
purposes.
3. Hazards Assessments
3.3 Identify and Screen Hazardous Chemical or Radioactive Material
3.3.1 Identification of Hazards
For most facilities, the basic source of non-radioactive hazardous
material inventory information will be the records and data bases that
support compliance with the reporting requirements of the Emergency Planning
and Community Right-to-Know Act (EPCRA), Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA).
3.4 Characterize Hazards
Information that describes and quantifies the hazards should be assembled
and documented to support the development of scenarios and analysis of
possible releases.
The maximum quantity of the material in appropriate units (pounds,
kilograms, curies, becquerels) and its storage or process locations. A
description of the conditions under which the material is stored or used,
including process systems or containers that hold the material and barriers
that may impact its release or dispersion, such as shipping containers,
buildings, berms, sumps, or catch basins.
The properties of the material that are needed for determination of
source term and consequence analysis, such as the physical form and chemical
characteristics of the material (e.g., solid, liquid, gaseous, particle
size, flammability, chemical reactivity, density), radiological
characteristics, and the temperature and pressure conditions under which it
is stored, processed, used, or transported.
Last Modified: February 1, 2008
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