INITIAL & ANNUAL CHEMICAL REPORTING

Posted on February 20, 2010 by BradKorth

WHAT ARE MY REQUIREMENTS AND WHEN?

Question: Why is Initial and Annual Reporting of Chemicals Required?

Answer: Reporting includes the Local Emergency Planning Commission (LEPC) which is typically the local Fire Department who are the First Responders if there is an on-site incident.  Reporting is required so that the LEPC is aware of the type of dangers present at the site.

Question: As an Auto Recycler what types of Chemicals May Require Reporting?

Answer: Typical Chemicals associated with Auto Recyclers’ which Require Reporting include:

  • Oil (stored in excess of 10,000 lbs, approx. 1,320 gallons)
  • Antifreeze (stored in excess of 10,000 lbs, approx. 1,100 gallons)
  • Gasoline (stored in excess of 10,000 lbs, approx. 1,600 gallons)
  • Diesel Fuel (stored in excess of 10,000 lbs, approx. 1,400 gallons)
  • Sulfuric Acid (stored in excess of 500 lbs, approx. 100 batteries)
  • Lead (stored in excess of 10,000 lbs, approx. 500 batteries)

Note: Reporting is based on the maximum quantity of the particular chemical stored on-site at any time during the calendar year.  Hence typically a good guideline to utilize is the “Potential” on-site storage capacity for that particular chemical.

 Question & Answer: When is Chemical Reporting Required?

  •  Initial Reporting: Whenever Maximum Quantity of a Particular Chemical is Stored on-site
  • Annual Reporting: By March 1st of the particular Calendar Year

Question: What are the Potential Penalties for Not performing Labeling & Reporting?

Answer: There is the potential of monetary fines from Regulatory Agencies if discovered during an Inspection.  However the most significant concern is Civil and/or Criminal Liability associated with an on-site Incident!

 For Further Information Contact Korth Engineering, LLC at:

CAR offers Container Labels Free to Members Meet Waste Management and OSHA requirements

Posted on September 24, 2009 by BradKorth

CONTAINER LABELING

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Requirement:

  • All containers containing used, scrap or waste materials must be properly labeled. Example items include: 1) pallets of used batteries 2) used oil in drip pans or in tanks 3) gasoline for on-site reuse or off-site disposal. Applicable labels need to address both Waste Management and OSHA regulations.

How Do I Know How To Label A Container?

  • First a material must be properly classified according to applicable waste regulations, which includes consideration of both the material type and ultimate use or disposal method. Then the proper label or labels can be selected.  A “Connecticut Auto & Recycling Industry Management & Compliance Program” guide has been prepared for CAR that specifies recommended labeling for various types of materials.


Are There Any General Guidelines For Container Labeling?

  • All containers from temporary containers such as drip pans to larger storage containers like pallets, drums or tanks need a Waste Management label (examples: “Used Oil”, “Gas”, “Universal Waste Used Batteries”). Hence materials need to be designated and segregated by material type and use / disposal method. The storage containers need to include a second label for OSHA purposes (examples: “Danger Windshield Fluid”, “Danger Corrosive Mercury”).   In particular cases an area can be labeled instead of, or in addition to, the container itself.


How Do I Obtain Labels?

  • CAR has made various types of labels to address both Waste Management and OSHA requirements available to members for free.  These labels address requirements associated with common types of materials and typical use / disposal methods.  A copy of the “Connecticut Auto & Recycling Industry Management & Compliance Program” guide is also available free to CAR members.
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