Facilities in New Jersey subject to the Community Right to Know (cRTK) program or Section 312 of the Emergency Planning and Community Right to Know Act (EPCRA) will be required to report based on updated hazard codes on the Community Right to Know Survey for 2017. Facilities may be subject to this program if they fall into certain industrial classifications or if they store certain hazardous materials above defined thresholds.
On March 26, 2012, the Occupational Safety and Health Administration (OSHA) published a final rule to revise the Hazard Communications Standard (HCS) due to its adoption of the Globalized System (GHS) classification and labeling of chemicals. GHS is a standardized approach for classifying chemicals by their health, physical and environmental effects, and this information is communicated to downstream users by consistently using signal words, pictograms, hazard statements, etc., on labels and SDSs (Safety Data Sheets). In June 2016, U.S. EPA finalized a rule revising the hazard categories in the regulations at 40 Part 370 for reporting under Section 312 of EPCRA. NJDEP is adopting the revised hazardous chemical guidance for the state’s Community Right to Know Survey.
All affected companies need to begin to track the hazards associated with the substances using the updated information on the substance’s Safety Data Sheet so that facility personnel will be prepared to accurately fill out the required reports in the upcoming year. Facilities in New Jersey will be required to report the new hazard codes for reporting year 2017. These reports will be due on March 1, 2018. The revised hazard classification system adopted by U.S. EPA is shown below:
Physical Hazard Health Hazard
Gas under pressure Acute toxicity-any exposure
Explosive Reproductive toxicity
Self-heating Skin corrosion/irritation
Pyrophoric (liquid or solid) Respiratory or skin sensitization
Pyrophoric gas Serious eye damage/eye irritation
Oxidizer (liquid/solid/gas) Specific target organ toxicity
Organic peroxide Aspiration hazard
Self-reactive Germ cell mutagenicity
Combustible dust Hazard Not Otherwise Classified (HNOC)
Flammable (gas/aerosol/liquid/solid) Carcinogenicity
These new hazard categories will be incorporated in NJDEP Online which is used to submit the Community Right-to-Know Survey.
Contact Baron Environmental with any questions or to have Baron prepare and submit the 2017 CRTK for your company.