CHEMICAL USAGE & REPORTING

WHAT ARE MY REQUIREMENTS & HOW DO I COMPLY?

As an Auto Recycler a variety of chemicals and petroleum products are stored and utilized on site.  Per the Emergency Planning and Community Right-To-Know Act (EPCRA) there are various regulatory requirements.  These requirements are not unique to Auto Recyclers as they are applicable to any business utilizing chemicals ranging from an office using cleaning supplies to a large manufacturer.

There are Four Typical Requirements which need to be Satisfied which are:

  • Container Labeling with Material Names and OSHA Information
  • Material Safety Data Sheets (MSDS) need to be available for All On-site Materials
  • Initial Reporting of particular Chemicals stored on-site
  • Annual Reporting of particular chemicals stored on-site

 How Do I Satisfy These Requirements?

 Container Labeling: Various Methods Available Including:

  • Containers Labeled by Vendor Selling the Chemical
  • Generic Labels with Required OSHA Information are available Free to CAR members
  • Obtain Labeling Information from MSDS

 Material Safety Data Sheets: Various Sources Including:

  • Available from Vendors who Supply the Chemical
  • Generic MSDS’s available from various Chemical Publications or various Websites
  • MSDS’s provided in the “Connecticut Auto Recycling Industry” “Management & Compliance” Program Guidebook (prepared by Korth Engineering, LLC) for Particular Materials for Waste Characterization purposes are also acceptable for satisfying OSHA Requirements

 Initial Reporting:Completion of Notification Forms and Submittal To Regulatory Agencies

 Annual Reporting:Completion of Tier II “EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY” Form and Submittal To Regulatory Agencies

For Further Information Contact Korth Engineering, LLC at:

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

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.