Calculating Reportables

Calculating Reportables

  1. The RAH System assumes all reporting is Mixture-based. Support for Pure Chemical reporting may be added in a future effort.
  2. RAH disregards inventory records marked as SARA 312 Exempt in CCM V8.
  3. Calculations are performed as follows:
    1. Convert all Inventory quantity Unit of Measures (UOMs) from the recorded UOM to Pounds (US).
    2. Determine the Maximum Quantity On-hand for each inventory period at a Facility for the Reporting Year.
    3. Sum the Max Qty On-hand quantities for all of the same-material inventory records for a facility
    4. Rounding occurs as the final step, after all other calculations and comparisons have been performed. all values are rounded to the 100th decimal place.
  4. System returns all material records which meet or exceed 10,000 pounds as a reportable material mixture.
  5. The system compares the list of inventory records against the EPCRA 302 List to determine which material records contain one or more EHS constituents.
    1. Extremely Hazardous Substances (EHSs) are designated under EPCRA Section 302, where the reporting threshold is 500 pounds (or 227 kg.) or the threshold planning quantity (TPQ), whichever is lower. (EHSs and their TPQs are listed in 40 CFR part 355, Appendix A and B)
    2. Chemical, or material ingredient, quantities are calculated using the Upper Concentration value identified on the (M)SDS and the Max Qty On-hand to determine EHS Chemical quantities. The EHS Chemical quantities are then aggregated across all material inventory records (using Max Qty On-hand values) for a facility and then is compared against the Reportable threshold (500lbs) or the TPQ, whichever is lower.
      1. i.e. A facility has 1000 lbs. of Green Goo, which contains the EHS Sulfuric Acid at 10% of the total composition. The same facility has 1000 lbs of Turbo Clean, which contains the EHS Sulfuric Acid at 50%. Therefore, the EHS Sulfuric Acid, totalling 600 lbs, is reportable, since it violates the 500 lb. EHS threshold for Sulfuric Acid.Green Goo: 1000 X .10 = 100 lbs.
        Turbo Clean: 1000 X .50 = 500 lbs.
        Aggregated Sum = 100 + 500 = 600 lbs.
      2. i.e. A Facility has 20,000 lbs of Turbo Clean Concentrate, which contains the EHS Sulfuric Acid at 10% of the total composition. This product would be reportable as it surpasses two different thresholds. First, it surpasses the 10,000 lb threshold for the material. Secondly, it surpasses the EHS threshold of 500lbs. In this case, the material will be listed as reportable and the EHS checkbox will be ticked on the report.Turbo Clean Concentrate: 20, 000 lbs.
        Sulfuric Acid: 20,000 X .10 = 2,000 lbs.
  6. EPCRA 312 Exemptions:

    1. EPCRA 312 exemptions can be applied at the material level and can be applied either in the Inventory Module or in the Reporting Module. If a Material is marked as Exempt, then it is reflected as such in the Inventory Summary interface and will not appear on the Tier II report outputs.
  7. Trade Secret
    1. If a material has an ingredient that is marked as trade secret then the material will also be marked trade secret and the ingredients will not be displayed in the report output.

Check out some of our most popular articles.

HazCom Signage

Since its implementation in 2015, OSHA’s Hazard Communication Standard has made OSHA-compliant hazard pictograms part of the visual landscape in U.S. workplaces. But are...

Read More

Rules For Proper Secondary Container Labeling

When a chemical is transferred from its original container to another, the second storage device is referred to as a “secondary container” or “workplace container.” Given...

Read More

Preventing Caught-in and Caught-Between Incidents

Caught-in/between incidents are among OSHA’s Big Four Construction Hazards, along with falls, electrocution and struck-by incidents. A report from the Center for...

Read More