Ordinance No. 20518 - Laserfiche WebLink

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E. MISCELLANEOUS 37. QUESTION: Is natural gas a reportable substance? ANSWER: Natural gas is exempt from the reporting requirement. Apart from the difficulties in measuring natural gas used in manufacturing processes, as opposed to non - manufacturing processes in the facility, virtually all natural gas is chemically altered in combustion, and the by- products are not reportable. 38. QUESTION: SARA Title III exempts a variety of products from reporting. 29 CFR 1910.1200 (b) (5) (iii) HAZCOM rules for SDSs exempts "any food, food additive, color additive, cosmetic, or medical or veterinary device or product, including materials intended for use as ingredients in such products (e.g. flavors and fragrances)." If I use substances for which there is no SDS requirement, am I required to track and report these materials? ANSWER: The Toxics Board has determined that substances are reportable if the manufacturer has evidence indicating that they are reportable, and are not reportable if the manufacturer has no such evidence. SDSs are one, but not necessarily the only, source of such evidence. Manufacturers are not required to seek such evidence beyond information that is readily available to them. However, the absence of an SDS does not in itself automatically exempt a substance from reportability (see Characteristic Substances section on page 12 for additional information). 39. QUESTION: EPA has exemption rules for de minimus quantities, often established for anything less than I% by weight of the total amount. Many paints, adhesives, inks, and other formulations have trace amounts of listed chemicals. Can we follow current, established EPA guidelines to ease the burden upon businesses in tracking quantities at these de minimus levels? ANSWER: No, because even concentrations of less than 1% can represent large quantities of reportable chemicals if the quantity of the mixture is great enough. Aside from the reporting thresholds themselves, there are de minimus exemptions only for contaminants which: a) belong to a SARA 313 chemical category and represent less than 1 percent of the total weight of a purchased material; or b) have no CAS number listed on an SDS. 40. QUESTION: The instructions indicate that waste aerosol cans are not reportable. Does this refer to cans with contents still inside? Also, please clarify whether the contents of waste aerosol cans are ever reportable in manufacturing processes. ANSWER: The contents of all aerosol cans are reportable under the same conditions as any other substance. The exemption refers only to the cans themselves. 41. QUESTION: Is ethanol produced by breweries reportable? -66-