Community Right to Know: New Hazard Codes

The Environmental Protection Agency’s (EPA) Emergency Planning and Community Right-to-Know Act (EPCRA) was passed in 1986 in order to require applicable facilities to report through the Community Right-to-Know (cRTK) Survey the storage and use of hazardous and toxic chemicals and to make their use more aware to the public and state and local agencies. The cRTK program also provides emergency planners and first responders with information about chemicals on-site in order to better assess and respond should a hazardous chemical release occur. This regulation stemmed from concerns from the 1984 pesticide plant disaster in Bhopal, India where a highly toxic substance was released, a half a million people were exposed to and the exposure caused thousands of deaths and injuries.

The cRTK survey for 2017 that is due on March 1, 2018 has been updated to reflect new hazard codes from the Globally Harmonized System (GHS). In 2012, the Occupational Safety and Health Administration (OSHA) revised the Hazard Communications Standard (HCS) to indicate the GHS labeling and classification requirements. GHS requires pictograms and hazard statements on labels and SDS that are standardized. In 2016, the EPA has finalized the rule for defining hazard categories to comply with GHS and the NJDEP is adopting this for the cRTK Survey.

The new hazard classification system that will be incorporated in the electronic reporting of the cRTK Survey is shown below:

Physical Hazard Health Hazard

Flammable (gases, aerosols, Liquids, or solids) Carcinogenicity

Gas under pressure Acute toxicity – any route of Exposure

Explosive Reproductive toxicity

Self-heating Skin Corrosion or Irritation

Pyrophoric (liquid or solid) Respiratory or Skin Sensitization

Pyrophoric Gas Serious eye damage or eye irritation

Oxidizer (liquid, solid, or gas) Specific target organ toxicity

(single or repeated exposure)

Organic peroxide Aspiration Hazard

Self-reactive Germ cell mutagenicity

In contact with water emits Flammable as Simple Asphyxiate

Combustible Dust Hazard Not Otherwise Classified HNOC

Hazard Not Otherwise Classified HNOC

Corrosive to metal

All previous reports included a series of six check boxes for the hazards of each chemical being reported. For the 2017 report, a total of 25 check boxes will be present. It will be necessary to utilize a GHS compliant Safety Data Sheet (SDS) to complete this report.

If you would like assistance with the 2017 cRTK survey or if you have any questions about the new hazard codes, please contact Baron Environmental at 908-508-9000 or email us at info@baronenv.com.

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